SUfTlARY AHD AflALYSIS OF COfTIBITS
                   ON THE
         NOTICE  OF PROTOSED RULB1AKING
                     FOR
         GASEOUS B1ISSION REGULATIONS
FOR 1983 AND LATER MODEL YEAR LIGHT-DUTY TRUCKS
        BMIWEfiAL PROTECTION AGENCY
      OFFICE OF AIR,  NOISE,  AND RADIATION
 OFFICE OF MOBILE SOURCE AIR POLLUTION COffl^OL
                   f-1AY 1990

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                                        EPA-420-R-80-101
       SUMMARY AND ANALYSIS OF COMMENTS
                   ON THE
        NOTICE OF PROPOSED RULEMAKING
                     FOR
         GASEOUS EMISSION REGULATIONS
FOR 1983 AND LATER MODEL YEAR LIGHT-DUTY TRUCKS
                  MAY 1980
   STANDARDS DEVELOPMENT AND SUPPORT BRANCH
     EMISSION CONTROL TECHNOLOGY DIVISION
 OFFICE OF MOBILE SOURCE AIR POLLUTION CONTROL
      OFFICE OF AIR, NOISE, AND RADIATION
     U.S.  ENVIRONMENTAL PROTECTION AGENCY

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                          Important Notice

     At the time we  performed  the  analyses  found  in  this  document
the rulemaking  was intended  to  be applicable  to  the  1983  model
year.    In  the very late  stages  of  the  rulemaking, EPA  decided  to
delay the  requirements  of the regulations until 1984.  Since  the
conclusions we  reached  remain virtually the  same  for 1984,  the
analyses  and recommendations have not been  changed.   For this
reason, the model year 1983 is used  as a  reference point thorughout
the document.

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                         Table of Contents


                                                           Page


I.    Introduction	ii


II.   List of Commenters	iii


III.  Analysis of Issues	/


     A.   Redefinition of "Useful Life"  	   |


     B.   In-Use Durability Testing  	   ^


     C.   Allowable Maintenance  	  7


     D.   Idle Test and Standards	/V
                                         t

     E.   Leadtime	


     F.   Economic Impact	


     G.   Technological Feasibility	7 £


     H.   Selective Enforcement Auditing 	


     I.   Nonconformance Penalty   	


     J.   Diesel Crankcase Emissions Control 	


     K.   Numerical Standards/Standards Derivation ....


     L.   Fuel Economy	


     M.   Environmental Impact	


     N.   Special Exemptions	

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I.   Introduction

     The Environmental  Protection  Agency (EPA) published  a  Notice
of Proposed Rulemaking (NPRM) on Thursday, July 12, 1979,  proposing
new light-duty truck emissions regulations for 1983 and later model
years.  The proposed rule prescribed more stringent hydrocarbon  and
carbon monoxide  emission  standards,  and  established a revised
assembly-line testing program and nonconformance penalty system  for
1983  and  later model  year  light-duty  trucks  as  mandated by  the
Clean Air Act  Amendments of  1977.   Substantial changes were also
proposed to the definition  of useful  life,  and  the procedures used
to verify  the durability  of emission  control  systems over  their
useful life.  Crankcase  emission standards  for  diesel  engines were
also proposed.

     This  document  presents  a summary  and  analysis  of  comments
received in response to the NPRM.
                                11

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II.
1.
2.
3.
4.
5.
6.
7.
8.
S.
10.
11.
12.
13.
14.
15.
16.
17.
18.
List of Commenters
Alaska Department of Environmental Conservation
American Motors
Glen F. Brammeier, NHTSA, DOT
Robert Chivvis, EPA Alaska Air Coordinator
Chrysler Corporation
Cummins Engine Company
Council on Wage and Price Stability
United States Department of Commerce
Ford Motor Company
General Motors Corporation
Doug Hansen, Director, Air and Hazardous Materials Div. ,
EPA
International Harvester Company
Motor Vehicle Manufacturers Association
Municipality of Anchorage, Alaska
New Mexico Cattle Growers Association
Toyo Kogyo Co, Ltd. (Mazda)
Toyota Motor Company, Ltd.
Volkswagen of America, Inc.
ADEC
AM


Chrysler
Cummins
COWPS
DOC
Ford
GM

IH/IHC
MVMA


Toyo Kogyo
Toyota
Volkswagen
111

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III.  Analysis of Issues

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A.   Issue:  Redefinition of Useful Life

     1.   Summary of the Issue

     In the  July  12,  1979 NPRM, EPA proposed  to  amend  the  current
definition  of  "useful  life"  for  light-duty  trucks.    Currently,
light-duty  truck  useful  life  is  defined as  five years or  50,000
miles (or the equivalent) whichever occurs first.   This  definition,
which applies to  all  light-duty trucks,  was  found to be inadequate
due to deterioration  of  the  emission  controls  of  vehicles  that  are
beyond 5 years  or 50,000  miles.  The  proposed revision  defines  the
useful life  as  the "average period of use up to the vehicle retire-
ment or engine  replacement or rebuild."  Since this period may vary
among manufacturers,  and among vehicle  types  produced  by  a single
manufacturer,  EPA  proposes  that  the  manufacturers  of a  vehicle
determine  the duration of this  period. The useful life is, however,
constrained  to  be not less than five  years  or 50,000 miles which-
ever comes  first, or  the  period of the.,basic mechanical warranty on
the engine  assembly, whichever  is longer.

     2.    Summary of  the  Comments

     A  large number of comments were  received regarding the EPA's
justification  for changing  the useful  life  definition  by noting
that  the half-life  concept  has  been a  part  of  vehicle  emission
regulations  since the 1966  (HEW)  rules applying to 1968 model year
vehicles.    In  that  rulemaking, 100,000  miles was  defined  as  the
basis for  "lifetime emissions." Under the assumption that emission
deteriorations  would be  linear,  HEW  established a  procedure  for
calculating average lifetime emissions at the  approximate half-life
(50,000-mile)  point.   All  subsequent  regulations  for light-duty
vehicles,  light-duty  trucks, and heavy-duty  engines, except for the
recently   adopted heavy-duty  engine  regulations,  have  used  half
of the expected life  as  the useful life.  The  commenters imply that
the  average lifetime emissions concept has embodied the intentions
of Congress throughout  the years and that the  proposed redefinition
of the useful life directly contravenes  Congressional intent.  They
contend  that Congress in drawing up  the 1970 Clean Air Act (where
the  term  "useful life"  first  appears)  was  fully  aware  that  the
50,000 mile "lifetime"  they  chose  for durability and  warranty
purposes  approximated only half  of  the  expected  life  of a light-
duty  vehicle.    The  half-life  concept  was  therefore  specifically
woven  into  the Act.   In further  support of these contentions one
commenter  states  that  an analysis  of  legislative  history of  the
 1977  Clean  Air  Act  Amendments clearly  shows a  rejection  of  the
total  life concept  now being  proposed  by EPA.

     Most   commenters  argued  against  the  concept  of  a  full-life
useful  life on  the basis that  it  acts  to increase the stringency of
 the  emission standards.   As  the  light-duty truck regulations  are
presently  constructed, manufacturers  must  design their engines so
 that  during approximately the first  half  of the  lifetime their
 emissions  do not deteriorate past  tke_level of  the  standards.

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i
  It  was argued that this situation requires  the  emissions  of a new
  engine to be somewhat below the  standard  in order  that  deteriora-
  tion  may be  accommodated.   The  proposed  full  life  concept  would
  purportedly  require  lifelong emissions compliance  and hence shall
  require  lower low  mileage  targets (LMT's).   This is the  "increased
  stringency"  referred  to in  the  comments.    Some  of  the  commenters
  went  on to claim  that  EPA is in effect  requiring  emission reduc-
  tions  in excess of the 90 percent set by Congress.

      The two  remaining  major areas  of  comment were directed  at
  specific problems  which  were  expected to  arise during  implemen-
  tation of the full-life concept.   The first of  these is  the  lan-
\  guage  of the  NPRM that requires  the manufacturers  to determine  an
•^"average" period of engine  use for each engine line.   The  comments
  imply  that  half of the  engines  subject to  an average useful  life
  will  require  rebuild or  retirement  before they  reach that  useful
  life.   Most  commenters  said  a  flurry of warranty  claims  could  be
  expected to result from decay in  emission-related components toward
  the end  of the useful life.

      The last set  of comments were  procedural in nature  and  cen-
  tered  around  the difficulties that the manufacturers would expect
  in  defining  a useful life number under the proposed  full-life
  concept.   First,  data  concerning actual  engine usage periods  is
  largely  unavailable  at  this  time.   Secondly,  it was argued  that
  the decision  when  to retire or  rebuild is reached by the  user  on
  largely  economic,  as opposed to  mechanical grounds.   Thus, manu-
  facturers would  find  it difficult to  arrive at  an average  period
  for this event for  an engine.   The problem  would be  further
  compounded  by the wide  range of vocational applications   seen  by
  many engine families.

      3.   Analysis of the Comments

      Many  of  the  issues  concerning  useful  life were  previously
  raised  in  connection  with the  1984 heavy-duty  engine  gaseous
  emissions rulemaking.   These issues  are  analyzed in depth  in  the
  Summary  and  Analysis of  Comments document  accompanying the  final
  heavy-duty  rulemaking,   and  are   incorporated  herin  by  reference.

\     The Clean Air Act  did not  place a  half-life  constraint  on
  light-duty  trucks'  useful  lives.   Quite  to the  contrary,  Section
  202(d)(2) clearly provides the Administrator with the discretionary
  authority  to define  the  useful  life of  light-duty  trucks  as
  greater  than  that set  by Congress for  light-duty  vehicles if  he
  "determines  that  a period  of  use of  greater  duration or  mileage
  is  appropriate."   Given  the disireability of  manufacturers'
  building emission control components as durable as  the rest of the
  traditionally long-lasting  engine parts,  and given  the significant
  air quality  benefits  that  will  be realized  if the  proposed defin-
  ition  of useful  life  is adopted, adoption of  the full useful  life
  concept  is  appropriate  and  well  within the discretionary authority
  explicitly granted to the Administrator by the Act.

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     Legislative history shows  no evidence  of a Congressional '
commitment to  impose a  half-life  limit on  the  useful  life  of
heavy-duty vehicles or light-duty trucks.  While  the 1977 Clean Air
Act Amendments deliberately defined  light-duty vehicle useful life
as half of the expected actual life, that decision was a result of
forces that were present  at that  specific  time  with respect to that
specific  class of vehicles.  A 100,000-mile/10-year requirement was
seriously  considered  by  a Senate  Committee,  but was subsequently
halved based  upon  the EPA staff's  analysis  of economic  and tech-
nological  feasibility.  Compliance with full useful life standards
is indeed possible and economically feasible  in 1983 for light-duty
trucks.  (See Section  1 of this  Summary and Analysis of Comments).

     Several  comments  implied  that  past  regulatory  practice
should constrain  future  rulemaking.   It  is EPA's belief, however,
that  regulations  must be  the  best attempt possible at  any given
time  to fulfill the  wishes of  Congress within  the context  of
feasibility,  cost, and other  factors. t  It was such constraints as
these which initially resulted in use of a half-life useful life by
HEW;  and  which led  to EPA's recent adoption  of full  life useful
life  for  heavy-duty  trucks in the rulemaking  for  1984 heavy-duty
engine gaseous emissions.

     The final area of comment which affects the full-life concept
itself is  the stringency  issue.   This idea might be better treated
in  the broad  context of how it  fits  into the total  full-life
useful life plan.   Given the  fact  that  the Administrator has the
authority to adopt a  full-life useful life, then a lower zero-mile*/
emission level  is simply a practical  result  of applying  that
requirement to the certification  process.  Thus,  we agree that in a
narrow  sense,  the  design-goal  emission  level  is  more  stringent
under  a  full  useful  life concept.  However,  the  standards them-
selves are not more stringent; they are  simply  met  for the  lifetime
of the engine.   The  staff cannot  accept the  stringency issue as an
argument against the  full-life useful life.   In any event,  Congress
required  standards  representing   a  reduction of "at least 90 per- >'
cent",  thus indicating  that  more stringent  standards  could be
promulgated,  provided they are technologically  feasible.

     The remaining discussion  will deal  with the practical diffi-
culties  associated  with  the  full-life  useful  life  concept.   The
first  of  those  is the proposed  requirement that  the  useful life
value supplied by the manufacturer be the  "average" for that engine
family.  The staff has considered alternative methods of establish-
ing the useful life number, though no commenter offered suggestions
along those  lines.    For example,  the alternative of  allowing
complete latitude in defining the useful  life  is likely to encour-
age  unrepresentative  values.  There would  be  a  somewhat  natural
trend for manufacturers,  favoring short durability programs and few
warranty claims,  to   gravitate  toward  a  lower  useful  life limit.
Another alternative could be  for  EPA to establish that some percen-
tile  of  the  retirement/rebuild distribution be  used  instead  of a
straight average.   This  option,  however^  suffers  from a  complete
lack  of  data  to  support  the  selection  of any  specific percentile.

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J
     The staff has concluded that  the useful  life value supplied by
the  manufacturers should be  an "average" for  a given  engine
family.  This  appears  to be the best way to determine useful life
keeping both industry and EPA's best  interest in mind.

     Regarding the  large number of warranty claims anticipated by
the  commenters,  the staff  disagrees that the  proposed  rule will
result  in  half of  the  manufacturers'  engines  requiring emissions
warranty work.   Although  it  is clear that  half will  reach their
individual  retirement/rebuild  points,  this  does  not  necessarily
mean an  emissions  violation will  exist in every case.   Certainly
there  could be additional warranty claims attributable  to  the
extension of the useful  life period.  The staff does not, however,
expect this number  to  be substantial.   Rather,  we  expect manufac-
turers to make  needed  changes in components to  provide  full life
durability  equivalent   to  their  present  50,000 mile  durability.
Costs for these changes have been  included in the economic analysis
of the  rulemaking.   Additionally, it was commented  that  the pro-
posed regulations  imply  that the manufacturer would be responsible
for post-rebuild emissions  compliance.   To  alleviate this problem
the staff recommends  a change in the  proposed  rule which defines
the end of  an engine's useful  life as the average period of use or
the  point  at  which the engine  needs  rebuilding, whichever is
reached  first  (provided that  the 50,000 mile/5 year  minimum  has
been passed).  Thus, the cost  of rebuild, as well as all subsequent
repairs,  will be  borne by the owner and not  the manufacturer.

     4.   Staff Recommendations

     On the basis  of comments  and their  analysis  above,  the staff
recommends  that the useful-life provisions as proposed be retained
largely  intact.   Three  significant  changes  are offered,  however,
which respond to a wide range  of comments.

     As we  concluded during  the  discussion  above, the  staff  be-
lieves that the full-life useful life concept should remain a part
of this  Rulemaking.   Within  the context, we  advocate that  the
language "average  period of use" be kept  intact for  the  sake of
practicality.  Since the manufacturers will  be  setting the useful
life values, EPA's requiring that  value to be an average appears to
be the most  reasonable method  of  encouraging accurate  useful
lives.

     Several  of the difficulties  associated  with an "average"
useful  life,  however,   will  be reduced  or  eliminated  if  certain
staff recommendations are  adopted.   Specifically, we  support 1)  a
set  of more  objective   criteria  for determining  when  rebuild  is
necessary,  2) a manufacturers'  option to  supply for the  owner
alternate expected  useful  lives depending  on service application,
and 3) modifying the "useful  life"  definition to be less restric-
tive of the manner in which the useful life is determined.

     The first of  these  suggested changes  is the most significant
and would remove  much  of the  uncertainty in defining  an "average

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period  of  use  up  to engine  retirement  or rebuild."    The  major
criterion  for  determining  whether an engine  is  due for a  rebuild /
would appear  on the label  and  would be, for the purposes  of  this
rulemaking, a  compression  test, along with  a measure of oil  con-
sumption and of bearing failure.  Those tests will cover nearly all
mechanical situations which normally signal the need for a  rebuild.
Since the actual test values will be determined by the manufacturer
for each engine family, establishing the average useful life should
be easier  and more  acurate. Another  implication  is  that  an  "actual
useful  life"  will  exist  for each  individual  engine;  there  will
be  a measureable  endpoint  to  the  manufacturer's  obligation  for
an engine with respect to both durability testing and the emissions
warranty.   Thus,  the  regulations clearly  will  not require  post-
rebuild emissions compliance.

     The  second recommendation  amounts  to  allowing  a  qualifying ^
statement  on  the label  to indicate  to  the owner  that  the useful
life  of this  particular engine can  be  expected to vary from the
"average"  due  to a  lighter or heavier  service  application.   The
label could  also direct the  reader  to  the operator's  manual  for
information about vocation-specific average useful lives, about how """
the  emissions-related  warranty  differs  from  the  mechanical  war-
ranty,  etc.   The  purpose  of the  label  change is  to  promote  user
understanding  of the  "average  useful life"  concept and hence  to
reduce the threat of warranty conflicts.

     The final  recommendation is to  remove  from  the definition.of
useful  life the restriction that for new engines the useful life be
determined from durability testing.   We see this  provision  as  an
unnecessary complication of  the  process of establishing a useful
life value.

     Some  of  our recommedations, particularly the  first two,  will
to  a certain  extent  add  to the complexity of portions of  the
regulations  and the  certification process as compared to  the
original proposal.   However,  the  staff  is  firmly convinced  that by
making  these adjustments to the proposal,  EPA will  not only answer
a  range of reasonable  comments but will  improve  the workability,
versatility, and fairness of  the full-life useful life concept.  We
urge the adoption of these  provisions.

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B.   Issue:  In-Use Durability Testing

     In order to better respond to comments on the proposed in-use
durability testing procedure and to optimize all components of the
program, EPA is delaying the  finalization of the in-use durability
testing requirements.  Further analysis of the  design of  the
durability program will continue and  finalization of the program is
expected to occur at the same  time as the  statutory NOx reduction.
The  Summary and Analysis of  Comments on  this  component of  the
proposal  are  not  included  in  this  document.    Instead,  comments
received will be  addressed  when the in-use durability regulations
are finalized.

     Beginning   in  1984,  and   continuing  until  finalization  of  a
revised  durability testing  procedure,  the  burden  of  durability
testing will be shifted to the manufacturers.   Under this  concept,
the  manufacturers  will determine  their  deterioration  factors  in
programs which  they  design.   EPA will  not approve  the  programs
which  the manufacturers  design but will require  that they:  1)
describe  their  durability  testing  program  in the  certification
application,  2)  certify that   their  durability  testing  procedures
account for deterioration of emission related components and  other
critical deterioration processes, and 3) adhere to the maintenance
requirements as applicable  specified  in the allowable maintenance
regulations.  These requirements  are the same as those proposed for
the determination of  the preliminary deterioration factor.

     Manufacturers are encouraged  to  begin small-scale in-use
durability programs  in the  near  future so they  can gain some
meaningful experience  with  in-use  durability testing.  This  will
benefit the manufacturers  and  EPA  in that they could generate
in-use  durability  data which  could verify  the feasibility of  and
need for an in-use  type durability testing program.

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C.   Issue:  Allowable Maintenance

     1.    Summary of the Issue

     Included in  Che  NPRM  were newly-proposed  provisions  to
limit the  amount  of maintenance which can  be  performed on light-
duty  truck durability-data engines.   Emission-related maintenance
must  be technologically  necessary  and must  have a  reasonable
likelihood  of  being performed by  owners in the  field.   Specific
minimum maintenance intervals are proposed which EPA has determined
to  be technologically  feasible.   Additionally,  "emission-related
maintenance"  and  "non-emission-related  maintenance"  are  defined.
These provisions will help ensure that in-use engines do not exceed
the  emission standards  as  a  result  of control  technology which
requires more  frequent maintenance than the users  will  actually
perform.
                                     ,t
     2.    Summary of the Comments

     Many  of the  comments  received  are similar to  the  comments
given on the  allowable maintenance provisions of  the Proposed 1983
Heavy—Duty Engine Regulations.^/   The three categories  which
encompass most of  the  comments are:  1) concerns  over EPA's justi-
fication, both legal and logical, for  imposing maintenance restric-
tions, 2) criticism of certain of the  maintenance  intervals, and 3)
comments on  the four criteria  for  assuring  "a resonable likelihood
of maintenance being performed in-use."

     Beginning with the legal issues,  several commenters questioned
EPA's authority to  establish "technologically necessary1' intervals
for maintenance.   The  commenters1  interpretations of §207(c)(3)(A)
and  §206(d)  of the amended  Clean  Air Act  (CAA) cited in the NPBM
as the basis of the provisions differed  from the  interpretation of
the  agency.   IHC interprets  §207(c)(3) (A)  to mean  that the manu-
facturer shall  furnish written  instructions for  the proper main-
tenance of the vehicle and does not indicate that the  Admini-
strator  is to make  any decisions  as to what  constitutes proper
maintenance. Ford  commented that EPA's scheme for controlling
engine  maintenance would  introduce  an  "impermissible degree  of
uncertainty  into  the emission certification process."   Ford felt
that the manufacturers would have no  means  to ascertain in advance
of  their  certification  applications   whether  EPA  would  classify
engine maintenance  operations  as "emission  related" or  not.   This
degree   of uncertainty is  unlawful,  Ford states,  according to the
recent Paccar decision,^/ in which the court noted:

     "Manufacturers are entitled  to testing criteria that they can
     rely upon with certainty."

In  addition to the legal criticisms commenters questioned the
logical  and factual basis  of EPA's  proposed  revisions.   General
Motors  criticized  the substitution ofvEPA's judgement  as  to what
maintenance  intervals  are necessary  in  lieu of  the manufacturer

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recommending maintenance intervals to the customers.   The  basis  for
criticism is that the reduction of vehicle maintenance has been  and
will  continue  to be  a goal of  the manufacturer.   Discussing  the
manufacturer's  role  in recommending  maintenance  intervals    AMC
stated,  "Restricting maintenance is  counter-productive to  air
quality  goals  and the  manufacturer' should have the  final say  on
what  recommended  maintenance schedules  should  be  followed by  the
owners."   AMC went  on to  say  that requiring the manufacturer  to
demonstrate  the  reasonable likelihood  of in-use  performance   of
maintenance  is  totally unrealistic and the fact that maintenance
may not  be  performed does  not  mean that it is unnecessary.  Both
Ford and IHC stated that the maintenance schedule,  as  set  up by  the
manufacturer,  is part of  the  competitive process  in marketing
because  the  customer  is  constantly demanding a product which
requires less maintenance.   Allowing EPA  to  recommend maintenance
intervals would destroy an incentive to minimize required mainte-
nance.

     One manufacturer  commented  specifically  on  the definitions
contained within  the  proposal as  being  illogical.  Ford criticized
the definitions  of  "emission related"  and "non-emission  related"
maintenance  and  "new technology"  as  being  inadequate  to inform
manufacturers whether  specific maintenance  operations, in addition
to those  listed  in  the NPRM,  may  be  performed at intervals rec-
ommended by the manufacturer, or  not at  all.  The  "new technology"
definition is objected  to  as  being a roadblock for a manufacturer
to introduce technology which  is new  to the  manufacturer.   In
applying this  technology,   if  it were  deemed by EPA as   emission
related,  the manufacturer would  be precluded from performing reason-
able maintenance.

     Basically all manufacturers  that commented responded that  the
technology does  not  exist  to meet  the proposed interval  require-
ments.  Toyota commented that they  are  not  confident  that  they  can
comply with the  1980 model year California light-duty vehicle
maintenance  intervals  which are  less  stringent  than  the  EPA pro-
posed intervals.  AMC is not aware of  any proven technologies which
reflect with any degree of  certainty that  oxygen sensors  will last
for 50,000  miles  or  that  catalysts will  last  for  130,000.   Ford
further criticized EPA  for  failure  to outline either  a description
of the improvements  required or  the basis for its conclusion that
such improvements  are feasible.

     Commenters  expressed   concern  that  EPA  has  arbitrarily  and
incorrectly  fixed  the maintenance  intervals  because  there is  not
any data  upon which  EPA may reliably predict  that  all  1983  and
later light-duty  trucks will require emission-related maintenance
no more  frequently than the specified  intervals.   Cummins criti-
cized EPA for setting maintenance intervals exactly the same as  the
heavy-duty diesel  engines.  Toyota indicated that EPA did not
describe  in  the proposal  any basis for  lengthening the intervals.
Toyota claimed  it does not have  enough  data  or experience in  the
field to meet  the proposed intervals  and  can only assure perfor-
mance with  the current maintenance services.

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     A substantial volume of  comment material  was  directed  at  the
more  technical   issue of  the  proposed  intervals  themselves.
For  gasoline  engines, comments concentrated on the intervals
proposed for  spark plug  and catalyst  replacement;  on  diesels,  the
comments addressed  the  turbocharger  and injector  maintenance
intervals.   Other areas of  comment  included  the  oxygen sensor  and
EGR system.

     The proposed 30,000-mile maintenance interval for spark plugs
was  criticized  as being unjustified  and unrealistic.    GM  had
concern  about  spark  plug life  in higher mileage  engines where  a
plug misfire could lead to the damaging  of  the  catalytic converter.
GM  also  mentioned that  light-duty  truck  operation produces  more
ignition events  in 30,000 miles  than  does  a passenger car because
of  the  generally higher  N/V  ratios.    No  commenter  believed  that
30,000  mile  spark plugs were  feasible over the entire  useful
vehicle  life.  During  the first  30,000 miles,  the  condition of the
engine  is  excellent  and  deterioration  is  neligible.  However,  as
mileage  is accumulated wear takes place which  in  turn could cause
shorter acceptable spark plug life intervals.

     All commenters  agreed  that  they are  unaware  of  the  required
technology to  guarantee  the 100,000 mile maintenance  interval  for
catalytic converters in LDTs.   GM proposes that  a lesser  interval
of  75,000  miles  would be  more  logical considering  the  extended
vehicle  life  of  130,000  miles.   Catalyst replacement at  75,000
miles will  provide  a  fresh catalyst  much  earlier  in the  service
life.  Several commenters believe that EPA has not established the
need  or  the feasibility  of the proposed 100,000  mile requirement
for  catalysts.   They  contend that EPA  data  on two passenger cars
(reported  in  MSAPC-79-211-B-4)  are inappropriate  for  LDTs  due to
the more severe service environment.   GM mentions  that even  in less
severe passenger car service occasional  replacement of catalysts is
required in order to comply with the 50,000 mile requirement.  The
U.S.  Department  of Commerce also took issue with   the 100,000 mile
catalytic converter replacement interval as being  unrealistic.  DOC
believes that the  LDT environment is more  demanding   and  that
technology  does   not  exist   for  100K mile  catalysts  in  passenger
cars. Therefore,  theyi  say,  it is unreasonable to  believe  LDTs can
meet  the 100,000 requirement.

      GM  comments  that  in  their  investigations  on  improving  cataly-
tic  converter life,  they discovered that oil off the cylinder walls
had  a greater degree of phosphorus toxicity for a  catalyst than oil
that comes .down through the 'intake  valves.  They stated  that
reduction in oil consumption is being worked on with the final goal
being longer converter life.  GM also states  that  catalyst deterio-
ration  evidence shows exponential decay,  so catalyst  decay is
expected to  be less in the second  50,000  miles  than  in  the first
50,000 miles of vehicle operation.

      Comments  were  also  received on^other  maintenance  intervals
proposed by  EPA.  Many manufacturers,  and  the U.S.  Department of

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Commerce,  criticized  the minumum life  requirements  of oxygen
sensors.  GM  particularly has concern for the  absence of  mainten-
ance on  the EGR system over  the  130,000 mile useful  life  of  LDTs.
IHC  and  Cummins  questioned  the  maintenance  intervals  for  turbo-
chargers   and  injector  tips.    Cummins  believes  the maintenance
interval for  turbochargers on LDTs should be investigated  and  may
be different than turbocharger maintenance intervals for heavy-duty
engines.

     The final area of comment is directed at the four satisfaction
criteria which  were  proposed to  assure maintenance performance in
the field.   Criteria (A),  (C), and (D) were criticized for  vague or
confusing language and criteria (B) for being illegal.

     If  the  only  option  available to  a  manfacturer is criterion
(B), then it  would be  required  to pay for the  maintenance.  Both
Ford and GM suggests that  such a requirement contradicts  §207(g) of
the  CAA by  placing  the maintenance burden on the  manufacturer
rather than the owner.

     Ford also  comments on the aspects of two   other criteria  (in
addition to  the use  of vague terminology).   Criterion (C), they
say, will not be applicable to a situation where the only change in
the recommended maintenance is to  adjust  the interval.  Also, Ford
reads criterion (D) to mean that when a signal  is used to encourage
maintenance performance,  the signal  must  be removed after  survey
data has been collected.   The data is  of "doubtful  utility" in such
a case.

     GM  commented that  the  options  other  than the  manufacturers
paying  for  maintenance are illusory.   Regarding criterion  (A),  GM
felt the purpose  of  scheduled maintenance  is to prevent the deter-
ioration of the part  to the  point that  irreparable harm is done to
other  components  and  to  insure  this result,"  the maintenance  is
scheduled with  an adequate  safety margin.   Based on  the  safety
margin, it is very unlikely that the part  will  fail "precipitously"
at the proposed interval.

     GM went on to criticize  criterion  (C)  claiming that even if a
manufacturer could demonstrate  that enough service parts  are sold
each year,  there  is  no  way  that maintenance  performance can  be
demonstrated in view of the  multi-faceted  aftermarket industry  and
do-it-yourself maintenance.  Additionally,  such  maintenance data is
simply not available and is not likely to  be available.
                                                           i
     Criterion  (D) is  criticized  by GM as being illogical  in that
there would be  no possibility of obtaining the  necessary  data  for
seven  to  ten years.   GM  further  pointed out   that the instrument
panel  is  space  limited  for  the  placement  of such  a  visual  signal
and only minimum necessary information should be required.

     2.   Analysis of the  Comments

     This section  presents the EPA staff's  di sens si on nr>_4  analysis
                                    10

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of the comments summarized above.  The comments will be treated in
the same order  that  they  appear in the Summary of Comments. Since
many  of  the comments are the  same as comments  received  on  the
recent heavy-duty rulemaking  proceedings,  the  reader is referred to
the analysis  done in  support  of that action  as  a further refer-
ence.^/  This section begins with an overview of EPA's position on
allowable  maintenance in general to provide a  context  for  the
discussion.

     By  restricting  the   amount  of  emission-related  maintenance
allowable  during  durability  testing,  EPA is  primarily  trying to
encourage an effort on the part of  the manufacturers to reduce the
amount of   owner  attention  that  their emission  systems  require.
This  encouragement fits into the  larger strategy of sustaining the
air quality benefits  of regulatory  actions as  the  vehicles/engines
are actually used.  Indeed, both the U.S.  General Accounting Office
and the Automobile Association  of America have recently pointed to
increased  light-duty vehicle  emiss'ion  system durability as an
approach  to better in-use  emission performance in those vehicles.4/
5/

     Certainly a  functioning network  of inspection-and-maintenance
programs  will  help achieve  proper maintenance in  the  field,  but
a  complete network  does  not  yet  exist for light-duty  trucks.
Likewise,  the  providing  of  clear  maintenance instructions  to the
user will also help to some extent.   Again,  this in itself is not a
total  solution  because the  nature  of emission control  systems is
often  such  that  the  operator is not aware that maintenance is due
or  that  it is necessary.   Thus,  manufacturers have a real oppor-
tunity to  help ensure in-use  emission-system performance  by pur-
suing long-lived designs that  require little  attention.   EPA
expects that once resources are directed  toward these design goals,
manufacturers  will be  able  to reduce required  maintenance  well
below that necessary for current technology  components.

     Section  206(d)  of  the  1977  Clean  Air  Act  Amendments (CAA)
directs  that  "[t]he  Administrator shall by  regulation establish
methods and procedures for making tests under  this  section," (i.e.,
tests  to  determine emission compliance).   It is  on  the basis of
Section 206 that EPA's entire certification  and durability programs
have  been   built,  as  well  as   the  Selective  Enforcement Auditing
regulations.

     The commenters show concern that there  is no specific Congres-
sional mandate  for EPA to establish minimum  technologically feas-
ible  maintenance  intervals  for durability test engines.  However,
the proposed maintenance requirements easily fall within the rather
broad  wording  of  §206.  Even certification and durability  testing
as  they  appear  in present  regulations  are  not  specifically de-
scribed  in  §206, yet  they  have  never  been successfully chal-
lenged.  The requirement for the  design of a  certification  program
is  that  vehicles and engines  be tested  "in such  a manner as
[the  Administrator]  deems appropriate"^ Sect ion  206(a)(D).   The
                                 It

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"appropriateness'1 of the proposed changes  is discussed later in the
context of the "factual basis"  comments.

     Among  the  responsibilities  of  the  Agency  under  §207(c)(3),
is  to  make certain that  the maintenance  instructions  provided  to
owners require  no  more maintenance  than necessary  to assure  emis-
sion compliance.  A manufacturer should  not be allowed to avoid its
warranty obligations by requiring excessive maintenance that is not
performed widely in the field.   This would result in the voiding of
many  warranties  because  of  a  failure to properly perform  the
maintenance even though such maintenance was not actually necessary
to  keep  the vehicle or  engine in compliance.   Therefore,  except
under  adverse driving conditions,  the maintenance required  of
the owners  to retain  their warranty should not  be more  than  that
performed during the certification testing.   The conclusion,  then,
is  that the maintenance  instructions should be  based on  the main-
tenance done during §206 durability  testing.

     Addressing   specifically Ford's comment  that  the scheme  for
maintenance introduces  an "impermissible degree of uncertainty  into
the emission certification process," the staff  feels that  the
comment is  justified.  Therefore,  the  staff  recommends  a  provision
be  included  specifying  a sufficient  notification,  similar  to
86.084-22 (e)(l) (ii),  to  reduce  the degree of  uncertainty on new
or  adjusted maintenance  intervals of "emission related"  com-
ponents.    The  new provision  would allow the  Administrator  to
specify new or adjusted emission related maintenance intervals  only
if  the  Administrator  has previously notified the manufacturer  of
the said  maintenance   interval   no later  than September  1  of  the
given calander year two years  prior to the model year.   Provisions
for an appeal process  should the manufacturers disagree with EPA's
decisions should also be included.

     The logical and factual basis for establishing technologically
feasible maintenance intervals   was  challenged from  several direc-
tions,  but little information  to substantiate the  claims was
provided.  We are  not  convinced  that  the degree of maintenance
required  to maintain  emission compliance is  widely performed,
especially  when  component  designs require frequent  attention  and
when performance of the maintenance does  not  improve driveability
or  fuel economy.

     Clearly  at the emission  levels  proposed  in this package,
proper maintenance  is  a key part of an  overall  in-use  emissions
control plan.   The weakness of  the present regulations  is the  lack
of  incentives for  the  required maintenance to  actually  get done.
The regulations  here   being  challenged address  one  facet  of  the
problem by encouraging  all  manufacturers to use the best technology
components possible from a low-maintenance requirement  standpoint.

     The staff  views   the  argument  regarding  market  pressures  on
component  durabilities to be somewhat  misdirected.   If lower
maintenance in some components   indeed provides a powerful competi-
                              10.

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tive advantage,  then  the market should be  an  important  factor in
designs beyond  today's  technology.   Generally,  however,  we  do not
believe  that  the market  pressures  for improved  durability in
emission-related components is strong.   (The durability of emission
controls has not been widely stressed  in advertising, for example.)
The staff is also concerned with the  implication that manufacturers
would be willing  to  trade  off improved  maintenance characteristics
and durability  (and  hence, a degree of better  maintenance  in the
field) for  commercial purposes.   We  cannot  accept the  argument of
the existence of market  pressures as a  rationale  for allowing more
frequent maintenance  than  present  technology  has  been shown to
require.   Conversely we do  hope that  the  pressures will,  in the
future be  a strong factor in encouraging continuing reductions in
the amount  of  maintenance  required on emission-related components.

     The  issue of  spark  plug  maintenance  intervals  will  now be
addressed.    A  majority  of the manufacturers currently  recommend a
maintenance  interval  range from 22,500 miles  to  30,000 miles for
light-duty  trucks  using unleaded  fuel.  Ford  specifies  a 30,000
mile spark  plug  maintenance  interval  for all  of  their  1980 light-
duty  trucks.    The  1984 heavy-duty vehicle regulations  specify a
technologically necessary spark plug  replacement  interval of 25,000
miles.   This  interval  came  as  the  result of  a fairly extensive
analysis  of heavy-duty  engine  operating  conditions  and  current
intervals.3/    Light-duty  truck application  is  less  severe   than
heavy-duty  application.   Thus,  the minimum necessary interval for
light-duty  trucks will  be  greater  than  25,000 miles.   The current
use of  a 30,000 mile interval by Ford  argues strongly in favor of
that number.

     Commenters  criticized  the  spark plug replacement  interval in
two major  areas:  higher  N/V  ratios when  compared to  light-duty
vehicles,   and  increased  oil consumption  on vehicles  with  high
mileage causing spark plug deterioration.

     There  is no justification to reduce the spark plug replacement
interval because of the higher N/V ratios of light-duty trucks  over
light-duty vehicles.   The  manufacturers' recommended interval
ranges of 22,500 miles to 30,000 miles for light-duty trucks is the
same as for light-duty vehicles.   Clearly,  if higher N/V ratios of
light-duty trucks over light-duty vehicles are a concern, the
manufacturer would have specified a lesser,  different interval  than
those specified for light-duty vehicles.

     G.M.  and  IHC point  out  that  light-duty trucks  with  high
mileage tend  to burn  more  oil  and cause increased spark  plug
deterioration.    This comment  is  unjustified when  reviewing the
current manufacturer  recommended spark plug replacement interval.
Current practice in the  industry does not recognize high mileage as
a  factor calling for reduced spark plug  intervals.   While the
manufacturers  recommend a reduced  maintenance   interval  for the
checking,  cleaning and  regaping of spark  plugs under severe opera-
ting  conditions,  the manufacturers'  maintenance  schedules  do not

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specify  a reduced replacement  interval  on spark plugs  as  vehicle
mileage  increases,  but  indicate  only one  spark plug  replacement
interval. Additionally,  G.M.,   in  another area of  comment,  states
"[T]he maintenance  is scheduled with an  adequate safety margin to
accommodate   some  portion  of the variation in part  and  in  the
manufacturer assigns "an adequate safety margin" in the  replacement
interval  and  does not  indicate  a replacement interval  reduction
with  increased  vehicle  mileage in  their  current maintenance sche-
dule, then the  manufacturer's  concern about  increased oil consump-
tion causing increased spark plug deterioration must be  overstated.

     Considering  the  spark  plug  interval for the  1984  heavy-duty
regulations and  the  arguments  given above, the staff does  not  see
any need  to reduce the  proposed 30,000 mile  spark  plug  replacement
interval.

     We  now  turn to  an analysis  of  the comments  relating  to  the
proposed  100,000  mile catalyst  replacement  interval.  The comments
generally took issue with EPA's extrapolation of light-duty vehicle
catalyst technology to light-duty truck application and  the lack of
data  supporting  the  proposed interval.   However, not one manufac-
turer supplied data supporting arguments that 100,000 mile replace-
ment intervals are unrealistic and cannot be achieved.

     The  staff  rejects  the  contention  that  light-duty  trucks  are
significantly  different  than  light-duty vehicles.   The  manufac-
turers, with exception  of  IHC,  use engines and catalysts  that  are
the  same  as in  light-duty  vehicle installations.   Obviously,  the
manufacturers cannot  claim  a significant  difference between light-
duty vehicles and light-duty trucks and yet use identical catalysts
for both applications.

     To  determine catalyst  replacement intervals,   a  best  estimate
must  be  obtained from the information available.   The  methodology
used to determine the interval  is well documented in the heavy-duty
vehicle  analysis.^/   A review of  the  specified heavy-duty  vehicle
catalyst replacement interval shows that  the light-duty truck
interval  is conservative.    Additionally,  AMC  recently  provided
100,000  mile  certification  data  on four light-duty  vehicles that
substantiated  the proposed  interval  is  technologically  feasible.
Three out of  the four vehicles indicated no  catalyst failure over
100,000  miles.   The catalysts  used on  these AMC  vehicles  are
considered to  be lightly  loaded,  i.e.,   a  low amount of  catalyst
material  per unit volume.   Lightly-loaded catalysts are  considered
to  be less durable  than  the heavy-loaded  catalysts  which may  be
used  on  light-duty  trucks.  Clearly,  if the  technology  exists  to
produce a lightly loaded catalysts  that  lasts for  100,000 miles,  a
catalyst design for light-duty truck application capable  of lasting
100,000 miles is  also feasible.

     The  staff disagrees  with  GM's  recommendation that a  lesser
replacement interval  of 75,000 miles be used  on  catalysts.   The
75,000-mile replacement  interval  would happen after  60  percent  of

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the new anticipated "useful life" of 120,000 miles occurs.   Clear-
ly,  the  replacement  interval  should be placed as close  to  the
vehicles' "useful  life" as  technologically  feasible in order  to
accomplish EPA's intent  of reducing the  amount of owner attention
to  emission  systems  and  sustaining the  air  quality benefits
as  vehicles  are actually  used.   It  is  doubtful  the  recommended
75,000-mile interval catalyst change with 60 percent of the vehic-
le's useful  life  over would be  done by  the  owner.   By specifying
the replacement interval, i.e.,  the 100,000-mile  interval, close to
the anticipated useful life, the staff's  concerns  that the catalyst
may not  be replaced are minimal.  In fact,  it is most likely that
such a  well  designed  catalyst  would  perform  for the  full useful
life without any replacement.

     In  addition  to  the  spark  plug  and catalyst  interval,  com-
menters  showed  concern  over the absence  of  maintenance  on  the EGR
system for  the useful life of  light-duty trucks.   The absence of
an  EGR maintenance  interval was accidental.    A  50,000 mile main-
tenance interval will be placed  on  the EGR valve. This interval is
supported by previous  studies and is the  same  interval specified in
the 1984 heavy-duty vehicle regulations.^/

     The minimum replacement interval of  oxygen  sensors was criti-
cized by the U.S.  Department of Commerce and many  manufacturers,
but  data arguing  against  the  50,000  mile interval  were  not  pre-
sented.  To  the contrary,  Ford  specifies  a 50,000 mile replacement
interval for their  oxygen  sensor used on  light-duty  vehicle appli-
cations and therefore  demonstrates  that a 50,000  mile oxygen sensor
is  technologically feasible for  light-duty vehicles.  Additionally,
the  1984 replacement  interval for  heavy-duty vehicle oxygen sensor
as  set by the  1984  heavy-duty vehicle regulations is 50,000 miles.
Light-duty- truck application  is considered  to be less severe than
heavy-duty vehicle  application.  With  the technologically  feasible
replacement interval for oxygen sensors  of 50,000 miles established
for  both  light-duty/heavy-duty  vehicles, the  need to  alter  the
50,000 mile  replacement  interval for  light-duty trucks can not be
justified.

     The final  area of  comment  regarding maintenance intervals is
specific  to  diesel engines and was  directed  to the maintenance
intervals  of the  turbochargers  and injector  tips.   Cummins  com-
mented that the maintenance intervals  may need  to be  different than
the  intervals  specified  for heavy-duty vehicles.  The staff recog-
nizes  that  light-duty  truck  engines  have shorter   lifetimes  than
heavy-duty  engines and therefore will reduce the maintenance
intervals  from 200,000 miles  to 100,000 miles for both turbo-
chargers and injector tips.

     We recommend that EPA delay the requirement  that manufacturers
must demonstrate "a reasonable  likelihood" that  proper maintenance
will be  performed in-use.  Our recommendation arises not  from
specific comments about these proposed  provisions but from  a belief
that such a  requirement  is  not  necessaty at this  time.  It appears

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 to  us  that the  manufacturers  would reasonably easily  be  able to
 show that  required maintenance was  indeed  being  performed on the
 emission-related components  which  these .regulations will  require.
 With respect to  the forthcoming  NOx  regulations, however,  the
 situation  is  different.   It is possible  that three-way  catalyst
 technology will be used, in  which case  oxygen  sensors will control
 the feedback  systems.   It is  for  this  type of component that the
 staff believes some sort of assurance of in-use maintenance will be
 necessary.    Regarding  catalysts,  assuming  they cost more than  2
 percent of  the  vehicle cost to  replace,  then  the manufacturer is
 required to  bear  the  cost  of  replacement  with or  without  these
 provisions.

     4.   Summary of Recommendations

     The staff has concluded that the proposed  maintenance  require-
ments (Section 86.083-25 of  Subpart A)  should be retained  in their
proposed form with the following exceptions:

     a.    A 50,000-mile EGR system maintenance interval should be
 included.

     b.    Include  a  provision to specify a.  sufficient notification
 to  the manufacturer  on new or  adjusted maintenance intervals of
 emission related components.

     c.     Delete  the  requirement  that manufacturers  must demon-
 strate "a  reasonable likelihood" that proper maintenance  will
 performed in-use.

     d.    Change  the  diesel  engine  turbocharger and injector
maintenance intervals to 100,000 miles.

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                            References

\J   1983  and  Later  Model Year Heavy-Duty Engines, Proposed
     Gaseous  Emission Regulation,"  44 FR  9494,  February  13,
     1979.

2l   "Paccar,  Inc. V.  National  Highway Traffic Safety Administra-
     tion, 573 F.2d 632 (1978).

3/   "Summary and Analysis  of Comments  to  the NPRM 1983 and Later
     Model  Year  Heavy-Duty  Engines  Proposed  Gaseous Emission
     Regulation," EPA,  OMSAPC, December,  1979.

4/   "Better  Enforcement  of Car  Emission  Standards  — A  Way to
     Improve Air Quality," Report  by the  Comptroller General of the
     U.S. General  Accounting  Office, Report IICED-78-180,  January
     23, 1979.

5/   American Automobile  Association  letter to Rep.  Henry Waxman,
~~    August  13, 1979  (EPA Central  Docket  Section #OMSAPC-78-4).

6/   See Issue G - Technological Feasibility.

7f   "Control of  Air Pollution from  New Motor Vehicles and Motor
     Vehicle  Engines:   Gaseous  Emission Regulations  for 1984 and
     Later Model  Year  Heavy-Duty  Engines,  45  FR 4136, January 21,
     1980.

8J   "Emission-Related Maintenance Intervals for Light-Duty Trucks
~    and  Heavy-Duty  Engines,"  R. A.  Rykowski,  EPA,  OMSAPC, Tech-
     nical Report No. SDSB-79-09,  January,  1979.

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D.   Issue:  Idle Test and Standards

     1.   Summary of the Issue

     EPA  has proposed  separate  certification  standards  and  test
procedures  for  the  idle mode  for both gasoline and  diesel  light-
duty trucks.

     2.   Summary of Comments

     The  manufacturers  agree  unanimously that  both the  proposed
idle test and the  idle  standard  are  redundant  since the  Federal
Test Procedure  (FTP)  currently includes  the  idle mode  as ap-
proximately  18  percent  of the transient  cycle.  Furthermore,  most
manufacturers agree  that  their  vehicles, since  they comply  with
FTP, will  inherently  meet the  idle  standards  and that EPA  should
therefore  withdraw  both  the  idle test  and  the  idle standard as
applied to light-duty trucks.

     Several  manufacturers identified  the  proposed  idle  test as
confusing and  insufficiently  defined.  Another major  concern
was  that  poor  correlation  between  the FTP and the  idle  test
would result in the requirement that  manufacturers  certify  vehicles
to two  different sets of standards.

     The  intent  of  EPA  in  requiring the  idle  test/standard was
also questioned.    One  manufacturer  indicated that  if  the  stan-
dard was  designed  to  evade  test  correlation  requirements  as re-
quired  under section 207(b)  it  was,  "against the  intent  of the
Clean  Air Act."   If designed for Inspection/Maintenance  (I/M)
purposes,  the question  was raised concerning the  development  of a
specific  I/M test  that would not require adjustment  of the  cer-
tification  process;  an  adjustment  that  would,  according  to the
commenters result in increased certification  costs.

     The  MVMA identified  two major  concerns  with  regard  to the
"supposed  desirability"  of   separate  idle  requirements.    First,
was the claimed lack of  control  over  testing conditions, equipment
calibration  and  personnel training which would, in  their opinion,
result   in questionable  test validity.  Secondly,  according to the
Association,  any  short   test  that does  not  measure all regulated
parameters,  ''could not be  employed to  invoke the warranty require-
ments of  Section 207(b),"  since  the  proposed test  does not measure
all regulated emissions.

     Additional comments include that:

     a.   EPA has not  established that CO "Hot Spots" exist  (jus-
tification is a requirement  if  these  "Hot Spots" are  the basis for
the idle test).

     b.   EPA has not established that a 90 percent reduction  in HC
and CO during idle is required to improve air quality.
                                 18

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     c.   EPA has not established that HC analysis  is required for
the idle test.

     d.   EPA has not  established that a separate  idle  test is  a
necessity for diesel vehicles.

     3.   Analysis of Comments

     Based upon  available  data the  staff agrees with the manufac-
turers  that  catalyst equipped vehicles have  the capacity to meet
the idle standards as applied to light-duty  trucks.   The  staff does
not, however,  view  the  idle  standard/idle  test as  redundant, but
rather  as  a  method  of  assurance  that  the available technology  is
actually controlling idle  emissions.   The  idle test  serves as  a
design criteria to  insure against any  tradeoff  of idle vs non-idle
emissions.    This criteria, we  believe can be  met  easily and for
little or no cost.

     The current FTP  for  light-duty trucks  was   designed with
measurement  of hydrocarbons  as  the  prime  consideration.  By its
nature  as  a  representative driving  cycle,  such a  procedure would
also be an accurate measure of other pollutants  being emitted
(such as CO).  However,  at  the same  time,  it may not be  the optimum
procedure  for  all  pollutants  in  terms of  their  environmental
impact, because  different  pollutants have different mechanisms  of
operation.   HC emissions combine  on  a  fairly  broad  scale, and over
a period of a  few hours participate  via photochemical reactions  in
the formation of  ozone.  CO on the  other  hand,  is  toxic  in  its own
right.   Highest concentrations  are typically associated with
morning and afternoon rush  hour traffic,  and can be highly  local-
ized.   The  driving  conditions  associated with central business
district rush  hour  traffic would have a lower average speed and
higher amount of  idle than does the FTP.   Also,  at  very  low  speeds,
tailpipe emissions can be substantially affected by  carburetor idle
settings.  The  idle test for CO  contained in this  rulemaking is a.
direct way of  insuring  that reductions in CO seen  on the FTP will
also occur  during  low  speed, high  idle  fraction operation  chara-
cteristic of urban rush hour driving.
                        i
     Furthermore, costs of  compliance with the  certification idle
test are minimal.  As  discussed above, catalysts effective  on the
transient certification procedure should  easily meet the certifi-
cation idle standard as a matter of course,  therefore, requiring  no
additional development  costs.  The only attributable costs  to the
idle test  procedure are those  associated with  performance   of the
actual  test  for  certification,  which  is insignificant  on  a per
engine basis.

     Diesel engines,  however, will  not be equipped with  emissions
sensitive  catalyst   systems.   Use  of  an idle  test procedure for
                               fi

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diesels, with or without in-use compliance testing, is expected to
have little or no effect.

     The staff also agrees that the necessity for HC analysis in
the idle test has not been established.  Therefore, it is recom-
mended that the HC idle standard be eliminated.

     The concern that was expressed that EPA is evading the 207(b)
requirements should be dispelled by the fact that warranty regula-
tions and the associated short test procedure have been recently
adopted in a separate rulemaking (45 FR 34802).  We do not rely on
§207(b) for authority for this idle test procedure.

     A number of specific technical issues on details of the idle
test procedure were raised during both this comment period and
the earlier comment  period  on the heavy-duty gaseous emission
regulations.  As  a  result,  a number  of  changes  are suggested
for  the  final  version  of  the  test  procedure of  Subpart  P:

     a.   The idle HC standard for gasoline engines will be de-
leted.

     b.   The limitations called for in 86.1511-83(a)(l)(i) and
(ii) will be adjusted from 45 to 90 percent, to 15 to 100 percent.

     c.   The interference gas  called for in 86.1511-83(a)(7)
should be N0£ at a 100 ppm concentration not NOx at a 1000 ppm.
Diesel comments do not apply here since Subpart P will apply only
to gasoline-fueled engines and vehicles.

     d.   A temperature controlled environment as referred to in
86.1511.83(b) is  defined  as  the  interior of a normally heated
room.

     e.   Section 86.1514-83(a)(2) is adjusted by the heavy-duty
procedure.

     f.   Utilization of the word "calibration" in section 86-
1516(b) is incorrect; "calibration " should be replaced by "span."

     g.   The average ambient temperature of the vehicle environ-
ment should be changed from -20CC to 45°C (-4°F to 113°F), to 2°C
to 43°C (35°F to  110'F).

     h.   Identification of operators in section 86.1542-83(a)(5)
and  (6) will not be deleted.

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     i.   Additive deterioration factors (DFs), are to be sub-
stituted for multiplicative DFs in the case of the idle test.  This
adjustment is being made due to nondetectable or very low emission
levels during LDT idles.

     In summary, the high percentage of time that all vehicles
spend at idle, the ease of an in-use idle procedure, the improved
effectiveness of  an  in-use  idle procedure in detecting failed
catalyst systems, and the virtually nonexistent costs of a cert-
ification idle standard support its promulgation.  No compelling
data at this time, however, support implementation of any idle
standard for diesel engines, and a delay in its promulgation is
warranted.  This decision could be reconsidered in the future,
should the need become mord evident.

     4.   Recommendations

     Retain the idle CO standard for gasoline  engines.  Delete the
idle  test  requirements  for  diesel  engines; delete the idle HC
standard for gasoline engines.

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E.   Issue:  Leadtime

     1.   Summary of the Issue

     In  the  NPRM,  EPA proposed  to implement  the  new  light-duty
truck  regulations  for  the  1983  model  year.   This  was based upon
EPA's belief at that time "that sufficient leadtime  is  available to
develop and apply the  necessary  emission  control  technology and to
conduct  compliance testing by  1983."    (44  FR 40792,  July 12,
1979).  The NPRM went  on  to  say,  "(t)herefore,  EPA  cannot make the
findings under  Section 202(a)(3)(C) necessary  to permit  consider-
ation  of revised  standards at  this  time."   At the  same  time,
however,  manufacturers  comments  on  the  feasibility of  compliance
with the  proposal  in  1983  were  solicited.   The request for such
comments stated  that "in order  that EPA  may  fairly evaluate the
technical merit of all  comments on feasibility,  the  Agency requests
that comments  be  accompanied by supporting data or other informa-
tion."

     2.   Summary of the Comments

     EPA received  a number of  comments on  the feasibility of
complying with  the  proposed 1983 deadline.   These comments fall
broadly  into  two areas:  (a)  technical  feasibility,  and (b)  legal
requirements of the 1977 Clean Air Act  Amendments.

     a.   Technical Feasibility of the  1983 Model  Year

     Comments on the technical  feasibility  identified  the proposed
standards  as  achievable for 1983  if viewed  in the  context  of
currently existing certification  procedures.   The  additional
aspects of the  proposal dealing  with allowable  maintenance, in-use
durability, redefined useful  life, and SEA were seen by commenters
as making  the  available leadtime marginally or wholly  infeasible.
An example of this position  is the following comment by GM:

     "General Motors is concerned that  there is  inadequate leadtime
     to asure compliance with the entire  regulatory  package.  While
     we  do  not  foresee  any  insurmountable  leadtime  obstacles  in
     incorporating" the "best  effort" hardware described in Section
     IV in time to meet start  of production  for 1983 MY light-duty
     trucks, this  does not  imply that  there is adequate leadtime
     allowed.   If  this "best  effort"  does  not  succeed in meeting
     the regulations as finally adopted,  further changes would have
     to be made.   At this point  in time, we do not know what this
     would  entail.   It may include  further  hardware  changes,
     revisions  to  production  techniques,  further improvements  in
     quality control procedures, or other things we  are  not now
     aware of.   Until we  have  experience with the "best effort"
     system under the  proposed  1983  certfication  procedures,  we do
     not "know"—we can only speculate ."_!/

     Comments  of  the  above  sort expressed  a.  lack of  information

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from  which to determine whether currently envisioned  emission
control  system changes  would be  capable of  meeting  the  overall
requirements  of  the  proposal.   These  comments are set  forth  in
greater  detail  in  the  analysis of  feasibility elsewhere  in  this
Summary and Analysis of Comments.

     IH  and Ford  developed  and submitted  specific  timelines  for
their  compliance  programs.    No  other manufacturers provided  such
timetables.

     The  IH schedule,  reproduced  here as  Figure  E-l,  led IH  to
conclude  that "such  timing   greatly  jeopardizes a  manufacturer's
chances  of  ensuring a certified produceable product line."2/   The
major time elements of the IH timetable are devoted  to  establishing
full life deterioration rates.  IH projected a need  for a  two  phase
testing program to establish  durability data and design systems for
extended  life.  Each  phase involves  the generation of  high  mileage
data  from a fleet  of vehicles.  The  first  phase is  intended  by IH
to  establish  basic  system  requirements.    The second  phase  would
involve  a fleet  of production prototype vehicles run  for the  full
usefull  life  to determine preliminary  DF's.   Together,  these  two
phases would require two years to complete.

     The  schedule  as  developed by  IH was  predicated  upon  promulga-
tion  of  the final  rulemaking  by  January  1,  1980.    It  contained  a
four  month  interval between the  two phases of the durability
program  for  supplemental  development or  redesign  required  as  a
result of the first  phase testing.   That four  month  interval  was
"not  considered  feasible"  to  accomplish  the necessary work.

     Figure E-2  presents the  timing plan developed by  Ford.   As
with IH,  the largest single element of the timetable  is the  program
for development  of durability data  (labeled  "useful life emission
development").   Ford projects  that  this  would  take approximately
two and  a half years to  complete.   The first  six months are  con-
sumed in assembling the prototype vehicles to  be  used  in  the
durability  fleet   (six  per  engine family).    This  is  followed  by
mileage  accumulation on  a  staggered basis  to reduce  the  testing
facility  load.    Comple.tion  of  mileage  accummulation would  then
occur over a six month timespan from the first to the last vehicle.
Ford  indicates  that  procurement  of  prototype  durability vehicles
would have had to  begin  by May 14,  1979  to allow time  for certifi-
cation to the 1983 model years.

     American Motors and IH both  argued that they  were  vendor
dependent  for  development of new control systems.    They  indicated
that  their corporations  lacked  the resources  needed to  develop
these  systems  for  themselves.   AM  stated that "the overall  regu-
lation would  be  unachievable even with the  most advanced concepts
presently under development of our passenger cars."5/  IH  indicated
their suppliers might be their own competitors.

     Both manufacturers  indicated  that bethg  vendor dependent  led


                                 20

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                                           Figure E-l

                                    IH LEAD TIME SCHEDULES/
       8/01/79
         8/01/80
                    8/01/81
               11/01
                       2/01
   5/01
11/01   2/01
  12/01  .   A/01
      8/01/82
5/01
IUMINGS
•83 STDS
-FINAL
 RULES?
                            100K MILES PRE-
                        IHMiLOPMnNT DURABILITY
                                                          13 MQMH DURADILI1Y VHIICLnS
                                                       DATA
                                                     VEHICLES
                                                 45
                                                 DAYS
                                                 ALL PAPER
                                                 TO DPA
                                                 FOR CiiRT.

-------
LIGHT TRUCK NPRM L  JFUL LIFE TIMING PLAN
1979 1980 1981 1982 1
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t 'if Mhi I) u'jii ui uff Y * • .- T_. T
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50K tMlSSIDM CEVEIOPMFH! Com*>ii'
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V T »
@f USEFUL LIFE EMISSION DEVELOPMENT
if- ------ 4 '• • • •
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JJASONDJFMJAMJJASONDJFMAMJ
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to  longer  leadtime  requirements  than  would otherwise be the case.
This  they felt placed them at  a significant  disadvantage.   AM
stated  that  they would  need  "at  least  two extra  years  of lead-
time...from the time  such demonstrated components are made avail-
able to us from our suppliers."

     Lastly,  the  Department of  Commerce  expressed the belief that
"(t)he advanced  engineering  phase  of  the manufacturers'  1983
light-duty truck  program is now well underway with  production
engineering scheduled to start  within the next few months.  There-
fore,  it  is  essential to establish  regulations to meet  the 90
percent reduction  objective that introduce  a  minimum  of  uncer-
tainty. %/

     b.   Legal Requirements of the  1977  Clean Air Act Amendments

     Commenters expressed the belief that in the  1977 Clean Air Act
Amendments,  Congress mandated  a  minimum four year leadtime appli-
cable  to  those light-duty trucks which  fall  within the statutory
heavy-duty truck  class.   (The  statutory  heavy-duty  truck class
includes light-duty trucks in the  6,000-8,500 Ibs  GVW class.)   As
stated by MVMA, "the  1977 Amendments and the accompanying legisla-
tive   history  unequivocally demonstrate  that  Congress intended to
require EPA to promulgate 1983  standards  so as to provide at least
four  years leadtime to  manufacturers.   There  is  not a  single
statutory provision or  element of  legislative  history  to  the
contrary."   They  stated  that  other provisions  of  the Amendments
(such as those for temporary or  permanent revisions under Sections
202(a)(3)(B)  and  202(a)(3)(E))  "indicate  that  Congress in  fact
intended  to override the  discretion as  to leadtime  otherwise
accorded to EPA by Section 202(a)(2)."7/

     To support this  position,  commenters  cited  provisions  of  the
Act, and items  of  legislative history.  Section 202(a)(3)(B) states
that "(d)uring the period of June 1  through December 31, 1978, in
the case  of  hydrocarbons  and  carbon monoxide,...the Administrator
may, after notice  and opportunity for a  public  hearing promulgate
regulations revising  any  standard prescribed as  provided  in sub-
paragraph  (A)(ii)  for any class  or category of heavy-duty vehicles
or engines.   Such  standard shall  apply  only  for the period of three
model  years  beginning four model years  after  the model year  in
which  such  revised  standard  is  promulgated."   The  standards  of
subparagraph  (A)(ii) referred  to here are the statutory 90 percent
reductions applicable to  1983  and later  model years.   These pro-
visions are  taken  by commenters to  mean that  EPA was to have
finalized  by  the  end of  1978  those  standards  which manufacturers
would  be  required  to meet in  1983 -  thus  allowing  four years of
leadtime for compliance.   Commenters  believed that this timetable
was  to be followed by EPA  even  if  the revision procedures  of
Section 202(a)(3)  (B) were not  being invoked.   If EPA was required
to  allow four  years  for  a relaxed (less  stringent) standard,  they
argued, then it would  be  illogical  for EPA not  to have to provide

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 four  years  for the  more stringent statutory reductions to  be
 implemented.

     As  further  support  for  the Congressional intent argument,  the
 following excerpt from Section  202(a)(3)(E)(ii) (which provides  for
 "permanent" changes in the statutory standards) was cited:  "No  such
 changed  standard  shall apply for  any  model year before the model
 year  four years  after the  model year  during which regulations
 containing such  changed  standard  are promulgated."   This  citation
 is  considered  a further  example of what  commenters  identified  as
 clear  Congressional  intent  for provision of  four  years  leadtime.

     Commenters also  felt  that  if a choice had  to  be made  between
 four years of  leadtime and  implementation for  1983,  that  the  four
 years  requirement  must be met.   As stated  by the  Department  of
 Commerce, four  years  "is  the time considered  by  industry  and  this
 Department as  the  minimum  in  which compliance  can be obtained
 without risking undue market disruption."8/

     MVMA cited  testimony provided before the House  and Senate  by
 both heavy-duty manufacturers  and EPA  in 1977 as  the  Amendments
 were being considered.   The  citation  indicated  that manufacturers
 stressed,  and  EPA  recognized,  the  need for  sufficient  leadtime.
 MVMA also cited  a  statement  by  Senator  Muskie in  November  of  1977
 which indicated a conference agreement for four years leadtime.   As
 originally adopted,  the 1977 Amendments  had specified June  1
 through  December  31,  1979  as  the  period during which  standards
 could  be  revised.   This  was later  amended  to  be June 1  through
 December 31,  1978.  Senator Huskies' explanation of this  change  was
 that it was made "so  as  to conform to  the conference agreement  for
 four years leadtime."9J  MVMA acknowledged that the 1977  Amendments
 do  not  expressly provide  for promulgation of the  statutory stan-
 dards in 1978,  but felt that this was the clear intent of Congress.

     3.   Analysis of the Comments

     a.   Technical Feasibility of the 1983 Model Year

     Aside from IH  and Ford, both of whom alleged  specific timing
 problems in  meeting a' 1983  compliance   date,  commenters presented
more of  a  feasibility problem  than  a  leadtime one.   For  example,
 the comment  from GM  indicated  sufficient time available to apply
hardware changes.  The doubt  expressed by GM  was  over the  adequacy
 of  their  "best  effort" hardware  to  do  the job.   Other  commenters
 supported this  position.

     The  issue of  feasibility is  addressed elsewhere  in  this
 Summary and Analysis of Comments under  "Technological Feasibility."
The analysis presented  there demonstrates clearly  the feasibility
of  the  final rulemaking  in  the form recommended by  the technical
 staff.   Thus,  the staff does  not consider the  comments of this sort
as  affecting the viability of the 1983 model  year,  as proposed  in
 the NPRM,  for   implementation of  the x£inal rules.   However,  the

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other  leadtime questions  raised by  specific  commenters  do need
careful consideration.

     1)   International Harvester

     The bulk of the  time  in  the  IH  leadtime  schedule  (Figure E-l)
is  devoted  to mileage  accumulation  on  durability  vehicles.   The
first  phase  (pre-development  durability  fleet)  is  scheduled  to
require  11  months,  and the  second  phase  (production  prototype
fleet) is scheduled  to require  13 months.   Both  the need for two
phases of testing and the time required  are questionable.  The need
for  this  program  was determined  largely by  the  proposed in-use
durability  requirements.   IH  felt that  "the  jeopardy inherent in
the  in-use  scheme  mandates  that  every attempt be  made to simulate
ahead of time, and as accurately as  possible, the estimated final
DF's"   In   light of  the staff recommendation  to  defer the in-use
durability  program at this  time,  it  is likely that  IH would no
longer feel the need for  a  dual durability  program.   The staff
believes  that  even with  an in-use program,  the need for such two
phase testing  was  not demonstrated by  IH.   No other manufacturer
indicated an intent to duplicate  their pre-certification  durability
testing.    The  staff believes that  the IH  timetable  should be
revised to eliminate the first phase  testing.

     In conducting its durability testing  of prototype vehicles,
each manufacturer will be  able to  design  the  type of  testing
program it  feels   is  most  appropriate.   Because  of  the latitude
available   to  the  manufacturer it  is  not possible to  quantify
the  exact  amount  of time this  process will require.   However,
the staff believes that  IH would have no incentive to undertake a
testing program more rigorous or time  consuming  than the current
light-duty  truck  mileage  accumulation  procedure.    Therefore,  to
estimate  the maximum  amount of time to prove  system durability and
establish   deterioration  factors  the  time   to  accumulate  full
useful life mileage  on  the  current light-duty  truck durability
schedule  will  be   used.   A  review  of records  on  durability data
vehicle mileage accumulation  from 1980 engine  families indicates 3
1/2 -  5 months as  typical  times  for accumulating 50,000 miles on
the EPA durability  schedule.   This  time  includes related aspects of
mileage accumulation such as  maintenance  and testing.  Allowing the
maximum of  5 months  would give  an  average  accumulation  rate  of
10,000 miles  per   month.   The average  useful  life  of  light-duty
trucks has been estimated by EPA as  120,000 miles.1Q_/  However, in
view of the  uncertainty of  this estimate,  coupled with an allowable
catalyst  change  interval  of  100,000  miles,   the  technical  staff
believes  that  the useful  life used by most manufacturers  for
certification will  fall at  approximately 100,000 miles.   If a
manufacturer indeed chose a lifetime longer than 100,000 miles,  he
would still  be able  to  end mileage  accumulation at  the catalyst
change .point.   A  new catalyst would substantially reduce exhaust
emissions.

     At 10,000 miles  per month,  it would  take 10 months to accu-

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mulate 100,000 miles.  Allowing  1  month  to prepare the durability
vehicle would  bring  the total time  to  11 months.   IH would  have
sufficient  time  to conduct  this  program and development  work  in
time for the 1983 model year if the  final rules are promulgated  by
June 1,  1980.   Development time would be restricted,  however,  if
the final rules are promulgated after June 1, 1980.

     2)   Ford

     Turning now to  the  Ford leadtime  schedule of Figure  E-2,
leadtime for development of durability data is once again the major
factor.   As with IH, Ford's extensive two and  one half year  dur-
ability program  was  principally  motivated by  the proposed in-use
durability program.  Ford proposed testing a sizeable fleet of six
vehicles  per  engine  family,  staggering  the  mileage accumulation
over six  months.   With the deferral of  the  EPA  in-use durability
fleet  requirements, Ford would be  expected to  return to a mileage
accumulation program characteristic *of   current  practice,  which,
as  noted, could  be completed  in  11 months.  Thus, Ford could
accomplish  the  desired  11/9/81  completion  date  of  Figure  E-2  by
starting  durability testing  before December 1,  1980 and  also
have six  months  development time  if the final rules  are  promul-
gated  before June  1,  1980.   Promulgation after June 1, 1980 would
restrict this development  time.

     3)   Vendor Dependency

     Both AM and IH claimed that their dependence  upon vendors for
development and  supply of  new control  systems  posed a significant
leadtime  problem.    The  EPA technical  staff believes  that  these
claims are greatly exaggerated.

     IH stated that "(c)ompliance with the proposed standards  will
require technological improvements  in the major  areas of catalysts,
fuel system,  air  injection, and  basic   engine  design  and  control
system parameters."  Contrary to this position, the staff analysis
of  feasibility  (see  Issue  G:  Technological Feasibility) indicates
that no major  innovations  are required.   In  fact, many 1980 Cali-
fornia light-duty truck models  appear  able  to  comply with the
recommended final rulemaking.   Data  submitted by AM for  high
mileage  catalyst  equipped  vehicles indicates  the  capability  of
their  current  systems to  perform  for  at  least  100,000 miles.ll/

     Vendor dependency may create some  time penalty even though  no
major  emission  control  system changes appear  to be required.
However, all manufacturers  experience this problem to one degree  or
another.   For example,  most manufacturers use  vendor supplied
catalysts and must  work with their suppliers when changes are
needed.   While  smaller  manufacturers such as IH,   AM   and  to  some
extent  possibly  Chrysler,  may be  somewhat more  vendor dependent
than larger manufacturers,  such  dependence is  minor  in consider-
ation of the available leadtime.

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     The  question  of vendor dependency  and  supply leadtimes also
arises  in connection with  the  Electronic Engine  Controls  (EECs)
which the staff is projecting to be used  to meet these regulations
without  incurring  a  fuel economy  penalty.   The staff  forsees  no
supply  problem  in  adopting  EECs as early  as  the 1983 model year.
In  fact, in  its  recently  proposed  fuel economy standards  for
light-duty trucks, NHTSA indicated its belief  that EECs  would  be
available for the  1982 light-duty truck fleet—one model year
earlier than needed here.  Respondents to NHTSA1s proposal did  not
challenge the feasibility of that date.

     4)   Advanced Engineering

     The Department  of  Commerce comment  concerned  the  meshing  of
EPA's  final  rulemaking  requirements with  the  advance engineering
which  DOC felt was  already well  underway, and with production
engineering which DOC felt was scheduled to begin "within the next
few months."  EPA technical staff agrees that each manufacturer is
entitled to as much advance  notice  of requirements as is reasonably
possible.   In evaluating the  adequacy  of  timing  in  the present
case,  the  staff turns  to comments of  the  affected manfacturers.
Apart from the DOC,  there were no other  comments  on this issue.   No
manufacturer felt  the  need  to raise  it as a  concern  from  the
manufacturer's  viewpoint.    Therefore,   the  staff   concludes  that
this concern  is  not a  valid  issue in  the context  of  the present
rulemaking.

     b.   Legal Requirements of the 1977 Clean Air Act Amendments

     The  technical  analysis just  completed  in Section a  above
indicates that compliance with the  recommended  final  rulemak-
ing  provisions  can readily be  attained  in  approximately two
years of leadtime before the model  year of introduction.   However,
we must now turn to  an analysis of  any  legal constraints placed  on
allowable leadtime by  the Clean Air  Act as amended  in  1977  (the
Act).  If, as maintained by commenters on the proposed rulemaking,
Congress mandated  a four year minimum leadtime for those light-duty
trucks  in the  6,000-8,500  Ib.  GVW  range,  then  the earliest  model
year for which the final  rulemaking could be applicable  for those
vehicles would be  1985.  The  EPA   staff  believes  that  four  years
leadtime is not mandated  for those vehicle.    Of course,  vehicles
below 6,000  Ibs. GVW are not considered heavy-duty vehicles  under
the statute,  and as  to  them,  there is  no issue concerning a stat-
utorily prescribed amount of leadtime.

     The comments  received on this   issue focused on the meaning  of
several portions of Section 202(a)(3)  of the  Act.  As  indicated  in
the Staff summary of these  comments,  the commenters believed  that
such provisions  must be  interpreted  as  requiring four  years  of
leadtime  for  heavy-duty engines or vehicles.    The staff rejects
this interpretation of the Act.  EPA interprets the statute and  its
legislative history  as  strictly requiring four years leadtime only

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in the case  of  revisions  to  the statutory  standards.   Although  it
could be  said Congress anticipated that standards under §202(a)(3)
(ii) would be promulgated at  such  a  time as  to be  in  place by the
last half  of 1978, this  assumption  was  never transformed into  a
direct requirement.  Rather,  what  was  expressly  required  was  that
the statutory standards  apply  to the  1983 model year.

     The same issue has  previously  been raised in comments  on EPA's
proposed gaseous emission  regulations for heavy-duty engines  (44  FR
9464, February  13,  1979).   In promulgating  the  final  regulations,
EPA delayed  the year  of implementation to 1984  based  upon  feasi-
bility considerations,  thus making the legal  issue  moot.   However,
EPA explained  the relationship between the need for  leadtime and
the 1983 implementation  date  as  follows:

     "It should be noted  that it is  the  Agency's view that had  it
     been  clearly evident that sufficient  leadtime existed  to
     permit  the  manufacturers to comply  with the  statutory stan-
     dards in  1983,  Congress1  desire  to  have the standards  take
     effect in the 1983  model  year  would have  taken precedence  over
     any expressions  concerning  leadtime to which the manufacturers
     might, otherwise have been entitled to  under Section 202." (45
     FR 4144, January 21,  1980)

     Indeed,  this  view  is consistent  with  Congress'  instructions
concerning the  possible  reduction  of emissions  in  excess  of  90
percent of baseline levels.  See H.R. Rep.  No. 95-294, 95th  Cong.,
1st Sess.  273  n.  13  (1977).    There, Congress recognized that  if
technology were to be available to achieve  reductions  greater  than
90 percent,  EPA was expressly authorized to  require its use.
Similarly, if  technology  will be  available  for  implementation  in
the 1983  model year, Congress  would not have   intended  that its
implementation be delayed.

     Clearly, EPA  cannot satisfy both the 1983 implementation  date
and provide  four  years  leadtime in  this rulemaking.   At such  a
point,  the  Agency must  find the optimum  policy for balancing
the environmental benefit versus the burden on  manufacturers.
The  goal which Congress surely  had in mind  in  incorporating
leadtime  guidelines  into  the act  was  to  insure manufacturers
adequate time to respond to new  standards without undue disruption
of their operations.

     The  four  year requirement for revisions  to the statutory
standards  undoubtedly  reflects  consideration of  the  relatively
major  changes  in control technology facing  manufacturers  of
heavy-duty engines (over 8,500  Ib. GVW).  These  engines  currently
use pre-catalyst  technology and  face the adaption  of catalyst
systems into  the heavy-duty environment.  The technical analysis  of
leadtime requirements  for these manufacturers completed as part  of
the final  heavy-duty  rulemaking concluded  that  four   years would
indeed be required to accomplish those tasks.

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     Those light-duty trucks which  fall  into  the  statutory heavy-
duty  class  (6,000  to 8,500  Ib.  GVW) face a totally  different
situation than that  just  described.  Indeed, Congress  recognized in
1977 that vehicles below  8,500 Ib. GVW present a somewhat different
set  of  regulatory  problems and accordingly,  expressly authorized
EPA to promulgate separate regulations  for  the class  of  light-duty
trucks.   See Clean Air Act,  Section 202(a)(3)(A)(iv);  H.R. Rep. No.
95-564,  95th Cong.,  1st Sess.  164  (1977) (Conference Report).
Even though most engines used in  these light-duty trucks are also
used in heavy-duty vehicles, the light-duty truck  applications are
more characteristic  of light-duty vehicles  than heavy-duty trucks.
Light-duty trucks are already employing oxidation catalyst systems,
and in some cases three-way catalyst  systems.   Their  emissions are
measured using the  same  test procedure  as  light-duty  vehicles.  In
actual use  they  are treated more  like cars than  like heavy-duty
trucks,  with most  owners  tending to view them  as "big  cars."

     For  all these  reasons,  the  task facing light-duty  truck
manufacturers in  complying with the statutory 90 percent reductions
is much less difficult than that facing heavy-duty trucks.   There-
fore, it  is  possible to provide adequate leadtime as Congress
desired  without needing a full four years.

     4.    Recommendat ions
     The EPA staff believes that in balancing Congress' desire to
implement  the  standards  for 1983 with its  desire  to  provide
four  years of  leadtime,  the situation at  hand dictates  that
the  1983 deadline  should  take precedence  providing that  the
necessary technology  and  sufficient leadtime  are  available.   The
issue of  available  technology is  clearly  presented  under "Tech-
nological  Feasibility"  and has been  demonstrated  as feasible.
However, providing manufacturers with sufficient  leadtime to comply
with  the  rulemaking  is  critical  in establishing  the  model  year
implementation date.

     The EPA  staff  recommends  retaining  the 1983  model  year
implementation date providing that the  rulemaking is promulgated by
June 1,  1980.   Recognizing that  the promulgation of the rulemaking
after June 1,  1980  would  place  an increasing pressure  on  the
manufacturer to  comply with the  rulemaking,  the EPA staff recom-
mends a  1984 model year implementation  if the rulemaking is promul-
gated after December  1, 1980.

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                           References

_!_/   Comments of General Motors Corporation,  October  11,  1979, pg.
     89.

2]   Comments  of  International  Harvester,  October   9,  1979,  pg.
     G-3.

JJ/   Comments  of  International  Harvester,  October   9,  1979,  pg.
     G-4.

_4/   Comments of Ford  Motor  Company,  October  11,  1979,  Attachment
     III to Section IV.

5f   Comments of American Motors, October 10, 1979, pg.  11.

6/   Memorandum of Comment  of  the  Department of Commerce, pg.
     17.

TJ   Comments of Motor Vehicle Manufacturers' Association,  October
     11, 1979, pg.  68

8/   Memorandum of Comment  of  the  Department of Commerce, pg.
~~    14.

9/   123 Cong. Rec. H  11957 (daily ed. November 1,  1977).

1Q/  "Average Lifetime Periods  for Light-Duty Trucks and Heavy-Duty
     Vehicles",   EPA Report  #SDSB  79-24,  Glenn W.  Passavant,
     November 1979.

\\l  Comments of  American Motors,  October 10,  1979, Appendix
     B.

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F.   Issue:  Economic Impact

     1.   Summary of the Issue

     The U.S. EPA has proposed a comprehensive control strategy for
1983 and later model year light-duty trucks.

     This  strategy  includes more  stringent HC and CO  emission
standards, a new  useful life  definition,  a revised durability
testing program, revised  allowable  maintenance  provisions,  and an
idle test with idle emission standards  for HC and CO.

     In addition, the control strategy includes a diesel crankcase
emission standard  for  light-duty trucks  powered by diesel engines
and  a  reduction in  the  Selective Enforcement  Auditing acceptable
quality level from 40 percent  to 10  percent.

     In the  proposal  the  EPA technical staff estimated an average
per  engine  first  cost  increase of  $62 (1978  dollars) with an
expected  operating cost  increase  of about $60  (discounted to
January 1,  1983) associated with inspection/maintenance programs.
The  rulemaking  strategy as a whole was  expected  to  cost approx-
imately $1.97 billion dollars  for the 20.4 million light-duty
trucks  sales  projected  for the  first  five  years  of  this regula-
tion.

     2.   Summary of the Comments

     The comments received on  the economic impact of these proposed
regulations will be summarized according  to the major components of
the  rulemaking  strategy.    The  following cost  areas  will be  ad-
dressed:  development and  emission control hardware, certification,
allowable maintenance,  useful  life  redefinition,  diesel crankcase
control, and the stricter  10 percent AQL.

     A.   Development and  Emission Control Hardware

     Several manufacturers  commented on  the specific  costs  asso-
ciated with  the  emission  control hardware  and  other developmental
costs associated with an emission control system capable of meeting
the  emissions standards for the full useful  life.   These  cost
comments are listed below by manufacturer.

     1.   Gasoline-Fueled  LDTs
International Harvester

Exhaust System and Related  Changes
Ignition System and Related Changes
Carburetion and Fuel System
Other

TOTAL                                       $198

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Ford

     Ford  estimated  costs  at about  $80  per vehicle, but  this  did
not  cover  the effects of  full useful life  or the  10 percent
AQL.

General Motors
     General Motors  estimated  initial  hardware  costs of  $362  per
vehicle.   This  figure  includes  $300  for  the  replacement of  the
catalytic converter and exhaust pipe.

Chrysler

     Chrysler estimated a  customer cost of $50 per vehicle with  a
50,000  mile  useful life  and tooling cost  of about  $500,000.   In
addition, Chrysler stated that the full useful life might force  the
use of three way catalysts and feedback carburetors.   In this  case,
the tooling cost was estimated at $20 million with a customer  costs
of  $315 per vehicle.   Chrysler estimated  emission control  system
development costs at four million dollars.

     Of  the other  manufacturers  none  commented  on  the  emission
control hardware costs in sufficient detail for analysis.

     2.   Diesel LDTs
     Of the  three  manufacturers  which  currently market  diesel  LDTs
none commented on  the  costs  of  bringing  these  engines  into compli-
ance.

     However,  for  the record,  Chrysler  provided costs  for  turbo-
charging light-duty trucks.

          Turbocharger Unit              -   $ 243

          Oil lines and other
            plumbing charges             -      27

          Change in injection
            pump configuration           -       9

          Manifold and turbocharger
            exhaust transition           -      46
                                 TOTAL:  -   $ 325

     B.   Certification

     No  manufacturer  commented  in  detail on  the costs of  recer-
tification.  However,  International Harvester commented on  the need
for very  complete  testing due to the  redefinition of  useful  life.
American Motors  commented that EPA's  certification costs  were too

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 low  because  too  many  ideal  assumptions were made.   American Motors
 did  not provide  any revised cost estimates.

     C.   Allowable Maintenance Provisions

     No  specific comments were received on  the  costs  of implemen-
 ting the allowable maintenance provisions.

     D.   Useful Life Redefinition

     The cost-related  comments  on  the useful life  redefinition can
 be divided into  two groups.   The first group is greater costs aimed
 at meeting the lower  target  levels  associated  with a longer useful
 life.  The second group is cost related to warranty claims.

     1.   Lower Target Levels

 Chrysler

     Chrysler  speculated  that  3-way  catalysts  and feedback  car-
 buretors might be necessary  to  meet  the  lower  target levels for HC
 and  CO.

 International Harvester

     Although International Harvester did not comment explicitly on
 the  lower target levels, they did state that the more sophisticated
 emission control systems  used  and  the  longer useful  life  period
 anticipated would  substantially reduce the  value  of their  current
 data on the durability  of their emission control systems.

jFord

     Ford  Motor Company  did  not  provide comment  in sufficient
 detail to allow  analysis.  They stated the extended  durability and
 revised  durability testing  procedures taken  together would  cost
 $420.   When questioned,  Ford  declined to  provide  further  detail.
 However, it appears that the bulk of the cost is tied up in  further
hardware such as: electronic engine controls, feedback systems,  and
 additional light-off catalysts.

     2.   Warranty Costs

     Several manufacturers provided  comments on increased warranty
 costs which  they expected as  a result of  the  longer  useful  life.
 These would  be costs  related to Section 207 of  the  1977 Clean  Air
Act Amendments.

 International Harvester

     International Harvester  provided in-depth  comments  on  their
 anticipated warranty  related  costs.   Referring to the  table  found
 in Attachment 4 to  their  written comments,  IH's costs  can  be

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 summarized  as  shown below:

      1. Probable Warranty Cost  (Parts and Labor)        :   $ 97

      2. Diagnostic Costs (116%  failure rate)
        ($23/hr x 2hr/diagnosis x  1.16 failure/vehicle) :   $ 53

      3. Dealer overhead and profit                      :   $ 65

      4. Average Engine Rebuild  Cost
        (100,000 - 130,000 miles)                       :   $ 71
                                                 TOTAL  :   $286

American Motors
     American  Motors expressed  serious  concern over  the  warranty
implications  of the  extended  useful life.   They stated  that  the
full  useful  life would  force each  new  truck customer to  incur  a
warranty  related cost  of $260  - $300  to cover  emission  related
warranty claims  in the second half of the vehicle life.

Ford

     No comments were received.

General Motors

     No comments were received.

     E.   Diesel Crankcase Control

     No comments related to the  control of  diesel  crankcase emis-
sions were received.

     F.   10 Percent Acceptable Quality Level (AQL)

     In general, few comments were received  on  the  costs  of imple-
menting a 10 percent AQL.   As  a group,  manufacturers felt  that  the
10  percent  AQL,  if  feasible,  would force  lower target  emission
levels and perhaps cause a fuel economy penalty.

     Chrysler commented  that  a  10 percent  AQL would  force  them to
incur  additional  testing costs.   These  costs would  include  a
one time investment  of $1.70 million dollars for testing  facilities
and equipment,  and  an additional $300,000 per  year  for  employees.

     Although comments  were  solicited on any increase in  internal
audit  testing  which might  be  required  by  the  10 percent AQL, no
manufacturers responded with any information.

     3.   Analysis of the Comments

     As can  be  seen  from the preceding section, very little
                             37

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substantial comment  was received from the  manufacturers.   Few
commentors replied  in  the detail requested in  the  NPRM,  and  only
minimal supporting cost breakdowns  were  given  by those who provided
specific cost-related  comments.

     The  EPA technical staff's analysis of these cost-related
issues will be  presented  on  a subject  by subject  basis similar to
the preceeding section.  In some cases  the methodology used in the
recently  finalized heavy-duty engine regulations will be utilized.

     The  costs  which  EPA  will  ultimately consider  chargeable  to
these regulations are  only those which are necessary  to  meet  the
requirements imposed by  these rules  and not  necessarily the total
which the manufacturers stated they may  spend.

     A.    Development  and Emission  Control Hardware

     When considering  the development and emission control hardware
costs related to the various  aspects of  this rulemaking package, it
is  important first  to  consider  the magnitude of  the task.   Based
upon  the  Technological Feasibility discussion  in Issue  G,  costs
will be incurred in the following areas.

     i.    Redesign and  Development  Testing

     Although the  technology  which will  be  employed  to  meet  the
target emission  levels  is  proven and well understood, development
costs will be incurred in improving the durability and reliability
of  emission related  components.   This includes  primarily  the
catalyst, air injection,  and  EGR.   Other related  components which
may be affected to a lesser degree include emission-related carbu-
retor changes,  electronic engine  controls,  and hardware used  to
control evaporative  emissions.

     In addition, the EPA technical staff expects  that some devel-
opment and testing  will be done by  the manufacturers  to optimize
the  engine/emission  control system  to achieve  optimum  engine
performance and  fuel  economy  and emissions compliance for  the
minimum cost.

     On a per engine basis the costs of improving system reliabil-
ity and durability as  well as  engine optimization should not exceed
$5-$10 per engine.jV  The EPA technical staff expects most of this
cost  will be spent on improving  the quality  and durability of
materials used in the  catalyst and  hoses related to the EGR and air
injection.

     In  most cases optimization  efforts  by the manufacturer
would yield  it  a net  benefit in terms  of  material  costs  saved or
marketability of  the  product.   In any  event,  optimization costs
would be  far less  than $1.00  per engine,  so  this  analysis  will
assume  the  optimization cost  is  included in the  $5-$10  estimate
cited earlier for redesign and development.

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    ii.   Emission Control Hardware

     As  stated  in  the technological  feasibility  discussion (see
Issue G),  the EPA technical staff expects that most manufacturers
will  use oxidation  catalyst/air   injection/EGR  systems  to  comply
with  the provisions  of the proposed  rulemaking.   In addition, EPA
expects  manufacturers  to  use  electronic  engine  controls  (EEC).

     In most cases,  changes to bring the vehicles  into  compliance
will  be  primarily the  addition of electronic engine controls and
changes  to catalyst  volumes and loadings.   In some  cases air
injection will  have  to be added   or  the less effective pulse air
system will have to be replaced by a  mechanical air  pump.

     To determine  more specifically  the costs related to  bringing
the LDT fleet into compliance with the  1983  emission standards the
EPA technical staff  studied the emission levels and corresponding
emission control hardware found in the*1980 LDT fleet.

     As of February 1980,  twelve light-duty  truck manufacturers had
certified  47 engine  families.   Of these  47 families,  16 were
Federal  families,  22  were  Federal  and  California  families and  9
were  California  only families.2/   Since engine families sold only
in California are certified to California emission standards,  these
families will be  eliminated  from  this  analysis.  When  appropriate,
certification results  for  California engine  families will  be used
to  indicate a possible emission control  strategy which would bring
the Federal family into compliance.

     The next  twenty  pages discuss  for each  manufacturer on  an
engine  family  by  engine  family basis  the   steps which  the  manu-
facturer may need to achieve the approximate  emission target levels
(.49 HC, 5.5 CO,  1.4 NOx) estimated by EPA.3/   At  the  end of the
discussion for each manufacturer is a table  outlining certification
data  for each  engine family.JL3_/    Data used  in  this  analysis  is
actual certification  data  for  1980 LDTs.  Costs in  the  Regulatory
Analysis will be based upon these strategies.

     a.  American Motors

     BT9A1 - Engine  family BT9A1  is  a  151 CID engine employing EGR
and a  pelleted  catalyst.   The  HC level is   below the target  level
already, and  the CO  and  NOx levels are within  0.1 g/mile of the
target levels.   This engine family can be brought  into  compliance
with  only  minor  engine calibration changes  or  electronic  engine
controls.

     Compliance  Strategy:   Use  engine calibration changes  or
electronic engine  controls  to  decrease CO  and NOx.   Air injection
does not appear necessary.

     CT3A1 - Engine  family CT3A1  is  a 258 CID/6 cylinder  with air
injection/EGR/and  a   160  cubic  inch  pelrteted oxidation catalyst.

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From  the  4K emission  levels  CO appears  to  be the major problem.
Changing  the  catalyst  volume  and loading would increase CO oxida-
tion.   In  addition,  a start  catalyst  may be  a  valid  measure to
reduce CO emissions,  however  the full  life  durability  of a start
catalyst  is questionable.

     Compliance Strategy:    Increase  the catalyst  loading to 2.2 g
and increase the catalyst  volume from 160 cubic inches to 200 cubic
inches.   Add  electronic  engine controls  to reduce  cold start
emissions.

     CT3H1 - Engine  family CT3H1 is  very similar to family CT3A1
and  uses  air  injection,  EGR, and a pelleted oxidation catalyst.
Some  of  the  4K emission  levels  are  below  the target  levels.
Increases  in  the catalyst  volume  and  loading,  together  with  the
addition  of electronic engine  controls would  decrease the emission
levels to near the target  levels.

     Compliance Strategy:    Increase  the catalyst  loading to 2.2 g
and increase the catalyst  volume to 200  cubic  inches. Use electron-
ic engine controls  (EEC)  to reduce  cold start and NOx emissions.

     HT3A1 - Engine  family HT3A1 is <±  304  cubic inch  8 cylinder
engine with air injection, EGR, and  a pelleted oxidation catalyst.
None of the emission  data  vehicles met  all of  the target emission
levels.   Increasing  the catalyst volume and loading would likely
yield the desired emission reductions.

     Compliance Strategy:    Increase  the catalyst  loading to 2.515
grams and increase the catalyst volume  to  260 cubic inches.   Use
EEC to control  cold  start  emissions and  NOx.

     NT3A1 - Engine  family NT3A1 is a  360  cubic inch/8 cylinder
engine employing EGR, air injection,   and  a pelleted  oxidation
catalyst.    Although  none  of   the emission data  vehicles met   the
target emission  levels, compliance with the target levels appears
easily  achievable  through increasing the  catalyst volume  and
loading,   and using the variable calibrations of EGR available with
EEC to control  NOx emissions.   These  catalyst  volume  increases also
will be necessary to  increase  catalyst durability.

     Compliance Strategy:   Increase the  catalyst  volume  to  260
cubic inches and increase  the  noble  metal loading to 2.515  grams.
More NOx  control can  be  gained  through  using modulated  EGR or
engine calibrations.   Use EEC  to   control  cold  start  emissions.
                                                                  I
     b.   Chrysler Corporation
                                                                 r
                                                                 ,'
     OTA-225-1-BCP - Engine family 225BCP is a 225 CID/6 cylinder
engine with air injection, EGR, and 2  small  oxidation catalysts.
None of the emission data  vehicles met  any of  the target emission
levels.   This   family  will  require increased  catalyst  loading  and
volume as well  as modulated EGR flow rates or a change in timing.

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    Table F-l




AMERICAN MOTORS
Engine CID/
Family Cylinders
BT9A1 , 151/4
CT3A1 258/6


CT3H1 258/6


HT3A1 304/8



-C

NT3A1 360/8



Emission Control System Catalyst Data
AIR EGR CAT Volume - Loading
- X P 160 1.555g
X X P 160 2. -i- 1.555g
/j . i- tr
*fU
X X P 160 i.i 1.555g
^ . < YS"

X X P 160 zs>s 1.555g
d • ?
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     Compliance Strategy:  Increase  the  catalyst volume to  150 CID
and  the  catalyst  loading should be increased to about 2.5  gram of
Pt per catalyst.  Use EEC  to  reduce  cold start  emissions  of HC and
CO, and permit the use of modulated EGR.

     OTA-318-2-BCA -  Engine  family 318BCA is a 318  CID/8 cylinder
with  air injection, EGR,  and 2  small oxidation catalysts.   A
compliance strategy  similar  to 225BCP should be adequate to  lower
emissions to  near the  target  levels.   Some of the emission data
vehicles  had  4,000 mile  emission data  values  near or  below the
emission  target  levels  estimated  by  EPA.    Modulated  EGR will be
necessary to slightly lower the NOx emission level.

     Compliance Strategy:   Change the catalyst  volume to  150 CID
and increase the platinum loading  to  2.5 grams.  Add EEC  to reduce
cold-start emissions, and use modulated EGR to reduce NOx.

     OTA-318-2-BEP -  Engine  family 318BEP  is a 318 CID/8 cylinder
engine with  air injection,  EGR, and an oxidation catalyst.   None of
the emission data vehicles met all of the  target emission  levels.
Increasing the  catalyst loading and  volume would  be  an  efficient
means of  reducing  HC and CO  emissions  to  near the target  levels.
Electronic engine  controls  could  be  used  to  control cold  start
emissions and would allow the use of modulated EGR to control
NOx.

     Compliance Strategy:  Increase the catalyst loading to  approx-
imately  2.0  grams  and  increase  the  catalyst volume  to  200  cubic
inches.  Add EEC to reduce  cold start emissions  and  NOx.

     OTA-318/360-4BCP  - Engine   family  318/360  BCP represents
318/360  8 cylinder  engines.    As  emission  control  systems  these
engines  employ  air  injection, EGR,  and  two small oxidation  cata-
lysts.   None  of the  emission  data vehicles met all of the  target
emission  levels,  although  the HC  and  NOx  values  were fairly low.
To decrease  the  HC and  CO emissions  a larger more heavily  loaded
catalyst should be used.  Electronic  engine  controls could  be used
to control cold start emissions and allow  the use of modulated EGR
to control NOx.

     Compliance  Strategy:    Increase  the  catalyst  volume  to 150
cubic  inches  and increase  the platinum  loading to 2.5  grams.
Use EEC to control cold  start  emissions and reduce NOx.

     OTA-318/360-4BFP - Engine  family  318/360 BFP  represents  a
318/360  8 cylinder engine.   For emission control  it  uses air
injection, EGR, a start  catalyst,  and a regular  underbody  catalyst.
Only CO  emissions  are above  the  current  target levels.   Increas-
ing  slightly  the  volume and noble metal  loading  in the  underbody
catalyst  will  yield  the  required reductions and  increased  dura-
bility.

     Compliance Strategy:   Increase  the catalyst loading to  about

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Table F-2




CHRYSLER
Engine CID/ Emission Control System
Family Cylinders AIR EGR CAT
225 BCP 225/6 X X M



318 BCA 318/8 X X M



318 BEP 318/8 X X M
t
*


318/360 BCP 318 & 360/8 X X M

318/360 BFP 318 & 360/8 X X M

Catalyst Data 4K Emission Levels
Volume - Loading - Metals - Ratio HC
2 @ 45 -f.r.615g Pt 1 .97
A isfi 1.05
.55
.58
.61
2 @ 45 *s .615g Pt 1 .51
.76
.74
.60
.52
141 i* 1.44g Pt 1 1.0
A.n- 1.1
(.*•• -80
.80
.66
.66
2 @ 45 /r.615g Pt 1 .85
.78
.71
22/141 -.>J .9/2.88g Pt 1 .40
/ i/ .46
.35
CO
14
13
10
11
12
5.4
10.8
6.6
12.5
6.1
9.0
10.8
15.7
12.8
12.8
8.6
9.2
14.1
12.5
8.8
8.1
7.5
NOx
1.6
2.2
1.5
1.6
2.0
2.3
1.2
1.9
1.3
2.1
1.5
1.3
1.6
1.7
1.7
1.8
1.8
1.4
2.0
1.2
.90
1.1

-------
3.0  g and increase the volume  to about  200 cubic inches.   The
required  reductions  could  be  achieved by  engine modifications but
this could be at  the expense of fuel economy.  Increasing the
volume and loading would also increase the emission control system
durability and diminish dependence on start catalysts.   Use EEC to
reduce cold start emissions.   Remove  the  start catalyst.

      c.  Ford Motor Company

     4.9 NA - Engine family 4.9NA represents  a 300 CID/6 cylinder
engine which  uses  air injection,  EGR,  and an oxidation catalyst.
One  of  the  emission data vehicles met  all of the target emission
levels with  the  current hardware, so it  could  be  argued  that no
incremental hardware  cost  is  required.   However, EPA expects that
Ford  will minimize  dependence  on  engine calibrations  which may
be causing a fuel  economy penalty.  Therefore, Ford  will  most
likely use either  EEC to reduce  NOx and  cold start HC  and  CO or
heavier  noble  metal  loading  to   increase  catalyst  efficiency and
durability.    We will conservatively  assume  that both  are  used.

     Compliance Strategy:   Increase noble  metal loading to 2.5 g to
allow  increased  control  and  durability.   Use EEC  to  reduce  cold
start emissions.

     5.0 NA - Engine family 5.0 NA represents a 302 CID/8 cylinder
engine which uses air injection,  EGR, and  an  oxidation catalyst to
control emissions.   Although none  of  the  emission  data vehicles met
all  of the target  emission levels the HC and CO levels are fairly
close already. Using a  larger catalyst with heavier loadings would
yield  the required  emissions reductions together with no  fuel
economy  penalty related to  HC   and  CO  reductions.   The use of
electronic controls will allow variable calibrations to reduce HC,
CO, and NOx emissions.

     Compliance Strategy:   Use the same  catalyst as engine family
5.0 NB (150 CID/2.17  Pt and Pd  in a  2:1 ratio).  Use EEC to reduce
cold, start and NOx  emissions.

     5.0 NB - Engine  family 5.0  NB  is very  similar to family 5.0
NA.   It's emission  data vehicles have HC and CO emission levels
below  the  targets  and the NOx  levels ^re easily achievable  with
variable calibrations of the EGR  available through EEC.

     Compliance Strategy:   Use  EEC  to  reduce cold start  and NOx
emissions.

     5.8 M/6.6 NA - Engine  family 5.8M/6.6 NA  represents 8 cylinder
351 and 400 CID engines.  These engines use air  injection,  EGR and
an oxidation catalyst.  Although  none of the  emission  levels  from
the  emission  data  vehicles met  all  of the target levels,  several
met  the HC and CO target levels.   Using a  slightly larger catalyst
with heavier  noble  metal loading  should bring  the desired HC and CO
reductions.    NOx reductions  should  be  achieved  through modulated
EGR.

-------
     Compliance Strategy:  Use  a  150 CID catalyst with 2.17 grams
of platinum  and  palladium  in a  2:1 ratio.  This is the same cata-
lyst as on family 5.8 WNG. Use  EEC  to  reduce  cold  start emissions.
EEC will  also allow the use  of modulated EGR which will decrease
NOx.

     5 .8 WNG - Family  5.8 WNG represents  a 351 CID/8  cylinder
engine which use EGR,  air injection,  and  an oxidation  catalyst.
It's HC and CO levels are already below the  target  emission levels.
Further NOx control is available through EGR.

     Compliance  Strategy:   To  gain  further  NOx control use modu-
lated EGR.

     d.  General Motors  Corporation

     08F2A - Engine family 08F2A  is a  250  CID/6 cylinder engine
which  uses  a  pelleted  oxidation catalyst,  EGR,  and a  pulse  air
system.  Although none of the emission  data  vehicles met all of the
target emission  levels, the  HC and  NOx levels are  close  to  the
target levels.   The CO  levels are considerably above the emission
target level  of  5.5g/mile.   Three steps may be necessary to bring
this engine   family  into  compliance:    1)   replace  the pulse  air
system with  a mechanical  air pump 2)   slightly increase  the cata-
lyst  loading  and  3)   add EEC to  implement  modulated  EGR  thus
reducing NOx. Adding more air will increase  the HC  and CO  oxidation
and adding modulated EGR will assure adequate  NOx reductions.

     Compliance  Strategy:    Replace  the  pulse air system  with  a
mechanical air pump.  Increase  the catalyst loading to 2.515 grams
of Pt and Pd  in  a 5:2 ratio.  Add EEC  to reduce cold start and NOx
emissions.

     08K4AA  - Engine family  08K4AA  represents  350 and 400 CID/8-
cylinder engines with EGR, air  injection, and  a pelleted  oxidation
catalyst.  Of  the four  emission data vehicles  three met the target
HC and CO levels but none met the target NOx standards.

     Compliance Strategy:   Increase the catalyst loading to 2.515g,
and use  EEC  to implement modulated  EGR and control spark timing.
Use EEC  to  reduce  cold start  emissions  thus  assuring HC  and  CO
compliance.

     Q8K4G - Engine  family   08K4G  represents  350 and  400  CID/8-
cylinder engines  which  use only  EGR and  a  pelleted oxidation
catalyst.  None  of  the emission data  vehicles met  either  the  HC
or  CO target  levels and only one met  the NOx  target.  The lack of
any air injection seems to be the cause of the  shortfall  in the HC
and CO areas.  The  0.2  to  0.3 g/mile  further NOx decrease required
can easily be achieved through modulated EGR.
                                                                /
     Compliance Strategy:  Add  a  mechanical  air pump or  at  least
pulse  air.   Achieve required  NOx reductions through modulated

-------
Table F-3




  FORD
Engine CID/ Emission Control System
Family Cylinders AIR EGR CAT
4.9 NA 300/6 X X M





5.0 NA 302/8 X X M





5.0 NB 302/8 X X M

5.8 M/6.ii NA 351 & 400/8 X X M



5.8 WNG 351/8 X X M


Catalyst Data 4K Emission Levels
Volume - Loading - Metals - Ratio HC
150 2.17g Pt/Pd 2:1 .57
.87
.95
.72
.49
.44
128 1.85g Pt/Pd 2:1 .49
.59
.73
.61
.58
.51
150 2.17g Pt/Pd 2:1 .41
.59
128 1.85g Pt/Pd 2:1 .39
.56
.78
.39
150 2.17g Pt/Pd 2:1 .34
.33
.49
CO
5.0
8.8
10
8.1
4.2
5.2
5.0
3.5
6.9
7.6
9.6
4.1
2.3
4.8
2.8
6.1
12.0
4.5
2.9
3.9
3.7
NOx
1.1
1.9
1.4
1.3
1.6
1.3
1.6
1.8
1.6
2.0
1.3
1.5
1.5
1.6
1.9
1.5
1.5
2.0
1.6
2.0
2.0

-------
EGR.   Add  EEC to aid  reductions  of  HC and CO  during  cold  start.

     08Y2A -  Engine  family  08Y2A is an 8  cylinder/305  CID  engine
with a pelleted oxidation catalyst and an EGR system.   None  of the
emission data vehicles  met the  NOx target levels but two met  the HC
level  and  one met  the CO.   From the emission data  available  it
appears likely that  the  required  HC  and  CO reductions  are attain-
able by  the addition  of  some  form of air  injection  and  variable
timing.   The  required  NOx reductions  can be achieved through
modulated EGR.

     Compliance Strategy:   Add a mechanical air pump.  Add  EEC to
reduce cold start HC and  CO emissions  and  allow implementation of
modulated EGR.

     e.  International  Harvester  Company

     4-196  -  Engine family 4-196  is  a' 196 CID/4  cylinder  engine
which  use  air injection, EGR,  and  a  pelleted  oxidation catalyst.
Certification data for this  family shows the HC level is  near
compliance, but  the CO and NOx  levels will  require  additional
reductions.

     Compliance Strategy:  Use EEC to  reduce  cold  start HC  and CO
emissions.   Increase catalyst  loading  to 2.2  g.  Gain NOx control
through modulated EGR.

     V-304  -  Engine family V-304  is  a 304 CID/8  cylinder  engine
using  air injection, EGR, and  a  pelleted oxidation catalyst.   The
emission data  vehicles  both  had CO  levels below the  emission
targets.   The HC  levels  are near  the target  levels  and the NOx
levels are somewhat  close.   To reduce  HC emissions a heavier
loading  is  necessary  in  the catalyst.  To reduce NOx emissions
modulated EGR is necessary.

     Compliance Strategy:   Increase catalyst loading to  2.515 grams
of Pt  and  Pd  in a 5:2  ratio.  Add EEC to reduce cold  start  HC and
CO  emissions.   EEC will also allow  the  use  of  modulated  EGR.

     V-345  -  Engine family V-345  is  a 345 CID/8  cylinder  engine
with air injection,  EGR, and a  pelleted oxidation catalyst.  The CO
emission levels  from  both emission data vehicles achieved the
target levels  and  the HC  level from one vehicle  is below the
target level.   This engine will  require a  heavier loading  in the
oxidation catalyst to lower  HC  emissions and will require modulated
EGR to reduce NOx without a  fuel  economy penalty.

     Compliance Strategy:   Increase  the catalyst loading from 1.555
to 2.515 grams of platinum and  palladium in a 5:2 ratio. Add  EEC to
control HC  and  CO cold start emissions and allow  the  use of modu-
lated EGR to reduce  NOx.

-------
Engine
Family
08F2A



08K4AA



08K4G



V?
08Y2A



Table F-4
GM
CID/ Emission Control System Catalyst Data 4K Emission Levels
Cylinders AIR EGR CAT
250/6 PLS X P
-


350/8 X X P


400/8 X X P
350/8 - X P



400/8 X P
305/8 - X P



Volume - Loading - Metals - Ratio HC
260 1.555g Pt/Pd 5:2 .56
.43
.53
.70
260 1.555g Pt/Pd 5:2 .59
.41
.36
.41
260 2.515g Pt/Pd 5:2 .55
.43
.62
.57
.54
260 1.555g Pt/Pd 5:2" .42
.53
.49
.57
CO
15.0
12.0
9.7
16.0
8.0
4.5
4.1
5.2
12.8
7.5
11.3
10.2
13.0
6.2
10.2
5.5
8.6
NOx
1.2
1.1
1.8
1.9
1.9
2.0
2.0
1.5
1.7
1.6
1.6
1.5
1.3
1.6
1.8
2.0
1.8

-------
           Table F-5




INTERNATIONAL HARVESTER COMPANY
Engine
Family
4-196
V304

V345

CID/
Cylinders
196/4
304/8

345/8

Emission Control
AIR
X
X

X

EGR
X
X

X

System
CAT
P
P

P

Catalyst Data
Volume
160
260

260

- Loading
1.555
1.555

1.555

- Metals
Pt/Pd
Pt/Pd

Pt/Pd

- Ratio
5:2
5:2

5:2

4K Emission Levels
HC
.5
.57
.61
.44
.57
CO
6.8
4.7
4.7
2.8
5.5
NOx
2.0
1.55
1.75
1.8
1.5

-------
     f.  Isuzu Motors

     AlTB  - Engine  family AlTB  represents a  111  CID/4  cylinder
engine with  air  injection  and EGR.   None  of  its  current  emissions
levels are  below the target  levels.   If this engine were sold  in
its  California configuration  nationwide all emissions would be  in
compliance.

     Compliance  Strategy:   Add  an oxidation  catalyst  similar  to
that used on the California version (160 CID,  1.555  g of  Pt  and  Pd
in a 5:2 ratio).  Add EEC  to  reduce cold start emissions  of  HC and
CO,  and reduce NOx emissions  through  modulated EGR.

     g.  Mitsubishi Motors  Corporation

     G52T-F - Engine family G52T-F represents  a 122  CID/4  cylinder
engine which uses EGR and a monolithic oxidation catalyst.  None  of
the  emission data  vehicles met all of the target emission  levels
but one did meet the HC  and CO targets.  The  California version  of
this engine  has  emissions  below  the  target  levels  for  all three
pollutants.  The major differences are  the  addition  of a  pulse air
system and engine calibrations.

     Compliance Strategy:  Add a pulse  air  system to reduce  HC and
CO emissions.  Add EEC  to reduce  cold start  HC  and CO emissions.
EEC  will also  allow  the  use of modulated  EGR to reduce NOx.

     G54T-F - Engine family G54T-F  is a 156 CID/4 cylinder  engine
which is  sold  only in the Federal  version.   It  uses  a pulse air
system,  EGR, and  a  monolithic oxidation catalyst  to control emis-
sions.    Of the  three  emission data vehicles,  one met  all of the
target levels,  two met  the  target  HC levels, and two  met the  target
CO levels.   Based on the data  from the emission data  vehicles, this
engine family can  meet  the new target  levels with only engine  or
emission control  system calibration  changes  or  the  use  of elec-
tronic engine controls.   However,  it  is  possible  that a mechanical
air pump may be necessary to replace the pulse air system  to  assure
increased oxidation of  the HC and CO which may be created by the
engine or  emission  control system calibration changes.   This step
is only  necessary as an added assurance  that  compliance will  be
achieved.

     Compliance Strategy:  Use EEC to  control  cold start  emissions
of HC and  CO.   Use  of  EEC will  also allow NOx  reduction . through
modulated EGR.

     h.   Nissan Motors
                                                                  /
     TL20F - Engine  family TL20F represents  a 119 CID/4  cylinder
engine which uses EGR,  pulse  air  and  a  small  monolithic  oxidation
catalyst.  None of the  emission data vehicles  met  all of the  target
emission levels.   Only  one  met target  NOx level and none met  the  HC
or CO  targets.   The California version  of  this  family uses a
                               So

-------
                                                      Table F-6
                                                     ISUZU MOTORS
Engine          CID/
Emission Control System
Catalyst Data
4K Emission Levels
Family
A1TB



A1TC

Cylinders
111/4



111/4

AIR
X



X

EGR CAT
X



X P

Volume - Loading - Metals - Ratio HC
1.3
1.5
1.4
1.4
160 1.555g Pt/Pd 5:2 .23
.26
CO
11.0
13.0
14.0
12.0
2.7
4.7
NOx
1.6
2.0
1.6
2.0
1.3
1.3

-------


Engine
Family
G52T-F

G54T-F



CID/
Cylinders
122/4

156/4

Table F-7
MITSUBISHI
Emission Control System Catalyst Data
AIR EGR CAT Volume - Loading - Metals - Ratio
- X M 61 2.5g Pd 1

PLS X M 61 2.5g Pd 1



4K
HC
.57
.75
.28
.16
.75
.28


Emission
CO
7.6
7.2
4.0
3.3
7.2
4.0


Levels
NOx
1.7
1.8
1.7
1.2
1.8
1.7

-------
mechanical  air  pump and  a larger, more  heavily  loaded  catalyst.
The California version of this  family met  all  of the emission
targets by a comfortable margin.

     Compliance Strategy:  Sell the California version nationwide.
This would  entail  the  replacement of the  pulse  air system with  a
mechanical air pump,  the use of an 80 cubic  inch catalyst  (as
opposed to 30) and an increase in  the noble metal loading from .44
to 1.86 grams of  platinum and palladium in a ratio  of two to one.
Use the variable calibration capabilities of EEC to  reduce HC,  CO,
and NOx as needed.

     i.  Suzuki

     LJ80 - Engine family LJ80 is  a 49 cubic  inch/4  cylinder engine
which  is  used  in small  land  rover type vehicles.   Its only emis-
sion control system  is  EGR.   The  EGR system allows  this  engine to
meet the target NOx  level.  Although the HC and CO  levels are well
above  the target levels, the addition of a pulse air system or, at
worst, a mechanical air  pump should  provide  adequate air  for
increased oxidation of  HC and  CO.

     Compliance Strategy:  Add  a   pulse  air  system  or air pump to
reduce HC or CO emissions.   If  any  additional  reductions  are
necessary these  should  be gained   through the variable calibration
capabilities of EEC.  The staff does not expect that an oxidation
catalyst will be necessary to  pass the  emission standards,  but it
    be necessary due to the idle standard.

     j.  Toyo Kogyo

     OMAT -  Engine  family  OMAT  represents  a  120  CID/4 cylinder
engine with  a pulse air system,  EGR,   and  an oxidation  catalyst.
The emission  data vehicle for this  family met  the HC target  and
barely exceeded the  NOx target.   The CO level exceeded the target
by 0.7 g/mile.   The California version  of this family easily  met
the target emission  levels using only calibration differences from
the system being used Federally.

     Compliance Strategy:   Use  the same  control   hardware  as  is
presently used,  but use  calibrations similar to those  on  the
California  version  or  preferably  the  variable calibration  cap-
abilities of EEC.   Replace the  pulse air system with a mechanical
air pump.

     QWBT -  Engine  family  OWBT  represents  a 140  CID/4 cylinder
engine which uses a  pulse air system, EGR and a pelleted  oxidation
catalyst.    Of  the three  emission data vehicles used  for  Federal
certification,  all met  the HC target  but only one  met  all three
emission  targets.    The  one  emission data  vehicle  which met  all
three  targets was sold  in all  50 states.  This engine family should
be able to meet  all of  the target  levels with the hardware current-
ly in use.

-------
  Table F-8




NISSAN MOTORS
Engine
Family
TL20F


CID/ Emission Control System
Cylinders AIR EGR CAT
119/4 PLS X M


Catalyst Data
Volume - Loading
30 .44g


- Metals - Ratio
Pt/Pd 2:1


4K Emission Levels
HC
.73
.83
.51
.62
CO
9.0
12.0
6.5
9.5
NOx
1.6
1.4
1.7
1.5

-------
Table F-9
SUZUKI
Engine
Family
CID/
Cylinders
Emission
AIR
Control
EGR
System
CAT
Catalyst
Volume - Loading -
Data
Metals - Ratio
4K
HC
Emission
CO
Levels
NOx
LJ80
49/4
1.0
12
1.4

-------
     Compliance Strategy:  Use the current hardware,  but  use EEC  to
gain  the reductions  required  to reduce  emissions  without  a  fuel
economy  penalty.   Replace the pulse  air system with a  mechanical
air pump.

     k.  Toyota

     2F(F) - Engine  family  2F(F) is a 258 CID/6  cylinder  with air
injection, EGR,  and a  pelleted  oxidation catalyst.   Both  of the
emission data vehicles met the HC target  level  but  neither met the
CO or NOx target levels.  The California version of  this  family has
emissions well  below all target  levels  and  uses a  heavier  loaded
catalyst of  the same volume.    The NOx control is  gained  through
minor calibration changes.

     Compliance Strategy:   Increase the  catalyst loading  to  that
which  is  used  in  the  California  version.   Use modulated EGR  to
reduce NOx emissions.

     20R(TC)  - Engine family 20R(TC) is a 134 CID/4  cylinder engine
which was certified  for sale in  all  fifty states in at least one
configuration.    The emission data  vehicle met  all  of   the  target
levels so this family can be considered in compliance.

     Compliance Strategy:  No action required to reduce  emissions.
EEC could be  added to  reduce dependence  on  fuel consuming  engine
calibrations  which  were used  to reduce  emissions   for  California
sales.

     20R(TF)  - Engine family 20R(TF) is the Federal  only  version  of
the 20R(TC) family.   This engine family  uses  air injection, EGR,
but no oxidation catalyst.  None  of the  emission data vehicles met
any of  the  emission target levels.   To  bring this family into
compliance an oxidation catalyst will  be necessary.  This  catalyst
should be similar  if not  identical  to the catalyst  used on  family
20R(TC).   In reality the likely outcome  is  the combination  of
families 20R
-------
    Table F-10




TOYO KOGYO (MAZDA)
Engine
Family
OMAT
OWBT

CID/
Cylinders
120/4
140/4

Emission Control
AIR
PLS
PLS

EGR
X
X

System
CAT
P
P

Catalyst Data
Volume
166
200

- Loading
1.82g
2.31g

- Metals
Pt/Pd
Pt/Pd

- Ratio
.84:. 16
.83:. 17

4K Emission Levels
HC
.40
.25
.37
.28
CO
6.2
2.8
7.3
6.5
NOx
1.5
1.1
1.6
1.6

-------


Engine
Family
2 F (F)
20R (TC)
20R (TF)




CID/
Cylinders
258/6
134/4
134/4


Table F-ll
TOYOTA
Emission Control System Catalyst Data
AIR EGR CAT Volume - Loading - Metals - Ratio
X X P 244 3.0g Pd/Pt 2:1
X X P 130 4.27g Pd/Pt 3:1
X X - - -




4K
HC
.44
.49
.16
.97
.65
.87
1.20


Emission
CO
8.7
9.5
5.0
13.0
10.0
12.0
14.0


Levels
NOx
1.8
1.7
1.2
1.7
1.6
1.8
2.0

-------
family 37PC were  sold nationwide this engine type would  come  into
compliance.

     Compliance Strategy:  Sell family 37PC nationwide.   A possible
option is  the addition  of EGR and a small air  pump  and  catalyst,
but this methodology could be  less fuel efficient.

     Light-Duty Diesel Trucks  (LDDT)

     Currently  three  manufacturers GM,  IH}  and VW are  certifying
light-duty  diesel  trucks for  sale in  the  U.S.   (see Table  F-13).

     Of  the three families  certified,  two, those  from IH  and  VW
already pass  the  target emission levels and will require  no addi-
tional reductions.

     The third,  GM's  350, easily  passe's  the CO  target  level,  but
does not pass the HC or NOx  levels.   This  engine is  basically the
same as  that  sold in  GM's  light-duty diesel passenger cars.   The
passenger  car  version must  meet 50,000  mile   emission  standards
which  are  more  stringent  than  the  LDDT target  levels.   The  EPA
technical  staff expects  that  the compliance strategy  used to bring
the LDD  passenger car  into  compliance will also  be used  on  the
LDDT.   This basically involves the addition of EGR and the redesign
of injectors  and other minor engine modifications estimated to cost
$30 per engine.kj

    iii.  Other Control Strategies

     Although the  previous discussion has dealt almost  exclusively
with  oxidation  catalyst/air   injection  systems  there  is  another
control system  available to  the manufacturers.   There  is  no doubt
that a three-way  catalyst  system could  also  be used to  meet  the
target emission  levels.   This three-way system would use  a  three-
way catalyst,  electronic engine controls,  and  a feedback carbure-
tor.   An approximate cost  for this  system on  a  300-cubic  inch
engine is shown in the attached table (see Table F-14).

     iv.  Summary

     The strategies discussed  for each light-duty truck  family will
be used  as a basic  input for the economic impact chapter  of  the
regulatory analysis.   The actual per vehicle cost for  each of these
strategies  will  be estimated using the data and methodology found
in a report prepared  under  contract for EPA.JL2/   The estimates  in
the report  have been adjusted for inflation, increased  real costs
of material,  and a more  realistic  overhead  and  profit margin.   The
profit and  overhead margin used  was  derived in  the  1984 heavy-duty
engine regulations summary and analysis of comments.

     B.   Certification

     As  a  result  of  these new  emission regulations, EPA expects

-------
                                                   Table F-12




                                                   VOLKSWAGEN
Engine
Family
37PF *


CID/
Cylinders
97/4


Emission Control System
AIR EGR CAT
X


Catalyst Data 4K Emission Levels
Volume - Loading - Metals - Ratio HC
- - 1.2
1.4
1.3
CO
6.1
6.5
5.7
NOx
1.8
1.8
1.5
Fuel 'Injection

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                                             Table F-13




                                LIGHT-DUTY DIESEL TRUCK EMISSION DATA
Manufacturer
GM
IH
LDT
Family
09J9Z
SD-33T
Percent of
LDDT Sales
76.16
3.62
Crankcase
Control
Yes
No
Emission
Turbo
-
X
Control
EGR
-
X
System
FI
X
X
4K
HC
.84
.82
.45
.39
Emission
CO
2.0
2.0
2.2
1.6
Level
NOx
2.0
1.9
1.6
1.4
vw
DP
20.23
Yes
X
.32
.90
1.1

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                            Table F-14

                   Three-Way Control Strategy  \J

               Three-way Catalyst           $181 2/

               Feedback Carburetor Mods         7

               Electronic Engine Controls    140
                                            $328

       less     Oxidation Catalyst           $117 _3_/

               Air Pump                        27
                                            $184 4/
_!/   Incremental cost over a 1980 system.

2f   A catalyst volume of 330 cubic inches with a noble metal
~    loading of 4.30g of Pt and .477g of Rh.

3/   A catalyst volume of 240 cubic inches with a noble metal
     loading of 2.31 g Pt and 1.16 g Pd was used.

4/   1980 dollars, includes profit at all levels.

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that most,  if not  all,  LDT  engine  families will  have  to be  re-
certified.    This  certification is  expected  to  be a  two step
process:  preliminary  deterioration factor  assessment and  testing
of emission data vehicles.

     Preliminary deterioration  factor  assessment  would most  likely
entail the testing of 1-2 durability vehicles per family  in an over
the road or  test  track usage.  The  cost  of  this  testing  will vary
by manufacturer depending  on  the  type of vehicle used,  the  number
of  durability  vehicles  per family and the useful  life figure
determined.

     In the economic impact analysis, EPA will use costs  in 3 major
areas:

     (1)  Prototype vehicle,

     (2)  Mileage accumulation to 100,000 miles,

     (3)  Emission testing  (28).

     In most  cases  a 1975 EPA memo  will  be  used to estimate these
costs.5J  However  the effects  of inflation  will be  accounted  for
by  increasing the  1975  costs by  38.2  percent  to  yield  1980 dol-
lars.^/  Based  on  this memo  and  the inflation  factor the costs of
preliminary deterioration  factor  should be  approximately as  shown
below:

     1.   Prototype vehicle:       $ 35K
     2.   Mileage and maintenance
          to  100,000 miles:          263K  3/
     3.   Testing (28)               12K  4_/
                                   $310K  per durability
                                          vehicle

EPA  expects   that on the  average each manufacturer  will run  1-2
durability vehicles  per  family.^/  This durability  vehicle program
will  be conducted  as part of the  development  program  described
previously.

     Emission data  vehicles are much less expensive to develop  and
run  to  4,000 miles.   Using  the methodology and memo used  above
these costs become:

     1.   Prototype vehicle        $13,800
     2.   Mileage and maintenance
          to 4,000 miles              8,800
     3.   Testing (2)                  800
                                   $23,400   per emission data
                                             vehicle

     EPA expects that on the average each manufacturer will run  two
durability vehicles and  four emission data vehicles per  family.

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These  costs  are higher  than those  previously  incurred during
certification primarily  due  to  the unknown  deterioration  charac-
teristics of emission control  systems  past 50,000 miles.

     C.  Allowable Maintenance  Provisions

     Although no  manufacturer  commented on  the  costs of  the  new
allowable  maintenance  provisions,  some  costs  will   be  incurred.
These  costs  are  primarily  related to  research  and development  and
improved materials.  Of  all the  items for  which  allowable  mainte-
nance  provisions  were  proposed,   only two  drew any  real  comment:
spark plugs and catalysts.

     The analysis of the  spark  plug  interval question (in Issue  C -
Allowable  Maintenance)  indicates  that  the  proposed  interval  is
within the range  of current  technology.   Therefore, the staff
expects  that  the spark  plug  interval is  obtainable at no  extra
cost.

     The catalytic  converter  interval of  100,000 miles drew  the
most general comment and  is where  the  greatest research effort will
be  necessary.   The  $5-$10 which  was  estimated earlier as an  R&D
cost should  go  toward  assuring the  durability  of  catalyst  systems
for  at least 100,000  miles.   This $5-$10 does  not include  any
changes  to  catalyst loading  which  might be necessary to meet
the  increased catalyst  durability  requirements.   The costs  for
increased  loading  were  inherently addressed  in the compliance
strategy discussion.

     D.  Useful  Life Redefinition

     1.  Lower  Target  Levels

     The change in the  useful  life  definition  will force  the
manufacturers to  achieve  lower target levels  in  their compliance
efforts than they would have had  the useful life remained at 50,000
miles/5 years.  The table below compares the target levels  for  the
50,000 and  100,000 mile useful life periods.   Both sets of  targets
assume a 10 percent AQL.

                     Emission Target Levels 3/
    50,000  mile  useful  life            100.000 mile useful life
    ~~HC0.57 g/mile                   0.49 g/mile
     CO        6.20                         5.50
     NOx       1.45                         1.40

     Although the NOx  target  level is  not  meaningfully  affected,
the HC and  CO target levels are substantially changed.

     The cost  of the  lower  target levels  could  be   estimated  by
determining the  effect  of the  lower HC  and CO  targets  on  the
actual hardware  used.  Three  main pieces of hardware  are affected:
air  pumps,  catalytic  converters,  and electronic  engine controls
(EEC).

-------
     Of the  8  families  which would  have  to add or upgrade their
present  air injection systems,  few, if  any,  would be  able to
achieve even the  50,000 mile  target  levels  without  these  systems.
This  can  be easily  judged by comparing the HC and  CO emission
levels of engines  with  and without air injection.   Air  injection
system changes  and improvements will  be  caused primarily by the
more  stringent  emission  standards  and not  the redefined useful
life.

     Almost  all families affected by these more  stringent  emission
standards will have to  increase their  catalyst  volume and/or
loadings  to  meet the  lower target levels.  The actual amount of the
cost  of  the increased volume or loading  directly  attributable to
the increased useful  life  is difficult  to estimate.

     To estimate  what  amount  of  the catalyst related  cost is
attributable to  the  longer useful  life,  it might  be helpful to
study the HC and CO  emission levels,and targets.   Although HC
oxidation occurs  directly in  the catalyst,  CO  (one  of the HC
combustion  products)  is  the limiting pollutant,  so CO will be
considered further.   The required reductions in CO emissions can be
viewed in two segments:   current levels  to  the  50,000 mile target
and further reductions from the 50,000 mile  target  to  the 100,000
mile  target.   Using the  concept of  segmented reductions,  the
catalytic converter cost  related to  the  useful  life can be esti-
mated.  To  estimate  this  cost the  only additional  piece  of infor-
mation required  is  the  current CO  levels of  the emission data
vehicles.    Using  the  data gathered  from  EPA'" Certification Divi-
sion  and  averaged  for each  engine  family,  the average CO  emission
level is  currently about 7.8 g/mile (see Table F-15).

     Total 100,000 mile  CO reduction:  7.8 - 5.5 = 2.3
     First  50,000 mile  CO reduction:  7.8 - 6.2 = 1.6

     Segmented Reduction:      1.6       =  .70  :First 50,000 miles
                              2.3

                              2.3-1.6   =  .30  :Second half of  life
                              2.3

     Using  the  methodology described  above,  the  conclusion  from
this  analysis  is  that about  30 percent  of  the catalyst related
hardware  costs could be attributable to the lower target  standards
and thus  the useful life.   When computing the cost effectiveness of
the  useful  life,  30 percent  of the  catalyst  cost  computed in
Chapter V of the regulatory analysis will be included.

     The   third  piece  of  hardware directly  related to  emissions
reductions are electronic engine controls (EEC).  EEC are a rela-
tively new technology for  maintaining or improving fuel economy and
engine performance while  lowering  emissions.  EEC  will  contribute
substantially to lower cold start emissions  due  to  variable timing
and  lower NOx  emissions  in  all  driving modes  as a  result of

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                                                        Table F-15
                                             Sales-Weighted Federal CO Levels
Manufacturer
AMC





Chrysler





Ford


^
7S


GM






Family
BT9A1
CT3A1
CT3H1
HT3A1
NT3A1

225 BCP
318 BCA
318 BEP
318/360 BCP
318/360 BFP

4.9 NA
5.0 NA
5.0 NB
5.8/6.6 NA
5.8 WNG

08F2A
08K4AA
08K4G
08Y2A
09J9Z


Sales
Weight
.0093
.0241
.0142
.0060
.0252

.0257
.0396
.0560
.0096
.0087

.0787
.1284
.0057
.0944
.0162

.0456
.1053
.1253
.0347
.0120


Avg 4K
CO Levels
5.6
9.7
5.2
7.1
11.4

12.0
8.3
11.6
11.9
8.1

6.9
6.1
3.6
6.4
3.5

13.2
5.5
11.0
7.6
2.2


Manufacturer
IH




Isuzu


Mitsubishi


Nissan


Suzuki


Toyo Kogyo


Toyota


VW

Family
4-196
V-304
V-345
SD33T

A1TB
A1TC

G52T-F
G54T-F


TL20F

LJ80


OMAT
OWBT

2F (F)
20R (TC)
20R (TF)
37 PF
DP
Sales
Weight
.0016
.0047
.0053
.0005

.0175
.0003

.0059
.0040


.0249

.0006


.0105
.0081

.0026
.0032
.0197
.0026
.0024
Avg 4K
CO Levels
6.8
4.7
4.2
1.5

12.5
3.7

6.3
4.8


9.3

12


6.2
5.5

9.1
5.0
12.3
6.1
1.0
Sales-Weighted Avg:   7.767 g/mile

-------
variable calibrations of EGR.  These EEC will probably prevent  the
need for the fuel consuming engine calibrations or start catalysts
used on many of the  California  engine  families.

     Although  it  cannot  be  stated unequivocally,  it  appears  that
the manufacturers will choose the use of EEC to control cold start
emissions and maintain fuel economy.   The start catalyst would be a
viable strategy for  a 50,000 mile  lifetime but  its durability for a
full lifetime would  be questionable.

     The incremental cost  of EEC  for  the  second  half  of the life-
time could be  estimated by determining the cost difference between
a start catalyst and a EEC system.

     A start catalyst used by Ford on its California engine family
5.0 NG would cost the consumer  about  $47 Tj and an EEC system would
cost from $44  to $60 depending on production volume.8/   From this
analysis there  appears  to be no inherent  additional cost increase
related to the  EEC.  A start  catalyst has  no  significant  cost
advantage and  EEC will yield many other benefits  to  the manufac-
turer and  owner for the  full  life.   The  EPA technical  staff con-
cludes  that  no  significant  portion  of the  EEC  is caused  by  the
lower  target  levels, so no EEC  cost will  be attributed  to  the
useful life redefinition.

     2.   Certification Costs

     Since certification will be required  for  the full useful life
it  is  reasonable that manufacturers will  run  their durability
vehicles  for  the full  useful  life.   If  the  full  useful  life  is
100,000 miles,  then one  half of the mileage accumulation,  mainte-
nance and testing costs for each engine family are attributable  to
the  full  lifetime.   Using  the  certification costs  described pre-
viously,  this  cost   comes  to $137,500 per  test  vehicle or about
$275,000 per engine  family.

     3.   Warranty

     Although  several  manufacturers  stated that per  vehicle  war-
ranty claims may exceedi $250, there  is one unstated but basic point
in their analyses which leaves  their  comment  open to some question.
In  the  past the  manufacturers  and vendors  of  emission related
components have  designed  and built  these  components  knowing that
their  responsibility  ends at  50,000  miles.    So  these  components
have been  designed   and  built  such  that  at  50,000 miles a small
percentage failure  is  acceptable.   EPA expects that manufacturers
will not  accept  the potential warranty claims  associated with
components designed  for a 50,000  mile lifetime,  but instead,  will
redesign  and  eventually  develop  emission  related  components  de-
signed  for a  full  vehicle  lifetime.  Under this concept,  the
manufacturers'  warranty claims  for a full  lifetime should not
exceed  that  for the  current 50,000  mile  lifetime.   This  is  true
because the  acceptable  failure  rate at  the  average useful  life

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should be  the same  as that  for the  50,000 mile useful  life.

     As described  briefly  earlier, EPA  expects that an average of
about  $5-$10  per vehicle will  be spent  in this redesign and
development effort.  This cost will primarily  affect the catalyst,
air pump, EGR,  and electronic engine control system, although some
lesser amounts  may  be spent on some  other  minor emission related
components.    This  $5—$10  estimate does  not  include  the  heavier
catalyst loadings described previously.

     In any case,  the manufacturers'  estimates  of increased war-
ranty claims should not occur  because  of the  revision in the useful
life definition from that which was proposed.  With the changes to
the proposed definition,  manufacturers will no  longer be liable for
engine rebuilds beyond their own warranty  period.

     E.   Diesel Crankcase  Control

     Of the three  light-duty  diesel  truck  families currently
certified,   the General Motors and Volkswagen families already have
closed crankcases.   The remaining family, that  from IH (actually
built  by Mitsubishi),  does  not  have a  closed  crankcase.   This IH
family is turbocharged  which  may  be the  the reason the crankcase
has not been closed.

     Mercedes Benz has  closed the crankcase  on both its naturally
aspirated   and  turbocharged  light-duty  diesel  engines using a
cyclonic separator  and a  few  hoses.2/    A  local  Mercedes  dealer
estimated  the  replacement  cost  for these  parts at  $6  per  engine,
which  seems  quite  consistent  when compared  to the cost of  other
crankcase  control systems.   A closed crankcase on gasoline-powered
light-duty vehicles costs about  $2 per vehicle^/ and on heavy-duty
diesel engines  this cost is approximately $10  per engine. 10/   The
estimate of  $6  per vehicle seems  reasonable in  comparison  to the
other  control"  systems,  and  will  be used  as  the  cost  to close the
crankcase  on the small number of IH diesels affected.

     F.   SEA Related  Costs
     The SEA related  costs  fall into  three major areas:   SEA
testing costs,  self audit  testing  costs, and 10 percent AQL compli-
ance costs.

     1.   SEA Testing Costs

     A decrease in formal  SEA testing costs is expected as a result
of the change in the AQL and  sampling plan.  This will result in a
change in the average sample number per audit from 16 vehicles per
audit to 13  vehicles per audit.  The change includes going from the
current batch sampling  plan  and  a  40 percent non-compliance rate to
a  sequential  sampling  plan  and a  10  percent  non-compliance rate.
On a per audit basis this  amounts  to about $1200.  On a per manufac-
turer or per vehicle basis  this savings  is  not substantial enough

-------
to receive  any  further consideration and  will  not be included  in
the final cost analysis.

     2.   Self Audit Testing Costs

     Although all major manufacturers were queried  as to what
increases in self audit  testing would be expected  with a  change  in
the sampling plan and AQL,  only Chrysler indicated that  they would
require more  testing.   Chrysler  estimated  increased  testing hard-
ware costs  of  $1.7  million and personnel  costs of $300K  per year.

     Manufacturers'  California audit  testing  data  available  to EPA
indicates that the manufacturers current compliance efforts  at a  40
percent AQL are already yielding compliance levels  near  or surpass-
ing that necessary for a 10 percent AQL. This data is discussed  in
the Technological Feasibility Issue (G).   Based  on this data the
EPA technical staff  can see no need for any  substantial  increases
in self audit testing.   However,  because Chrysler  responded  in the
affirmative in  the  area  of further testing,  their costs will  be
included in the final economic impact analysis.

     3.   10 Percent AQL Compliance Costs

     Due to the test  to  test  variability of emissions data  and the
more stringent  10 percent AQL, manufacturers will probably  try  to
achieve lower  target  emission levels than  might be sought  at a  40
percent AQL.

     Using variability of  10  percent (HC),  20 percent (CO),  and  25
percent (NOx)  the EPA technical  staff  has  estimated  target  levels
for a  40  percent  AQL and  a 10 percent  AQL assuming in each  case a
100,000 mile useful life.

                        Emission Targets _3/

              40 Percent AQL               10 Percent  AQL

          HC        0.53 g/mile              0.49  g/mile
          CO        6.4                      5.5
          NOx       1.7                      1.4

    To determine  any hardware costs related  to going from the  40
percent AQL to the 10 percent AQL it must be determined what  if any
hardware changes  may result from the slightly  lower  target  levels
anticipated.

     There  are  four basic  pieces of hardware  which  must be con-
sidered:  air  injection,  EGR,  catalytic converters, and  electronic
engine controls.

     Of the families which need to  add  or  upgrade  an  air  injection
system, it  does  appear that  perhaps  one GM  family (08Y2A) may  be
able to meet  the  target HC and CO  levels  with  the use  of a pulse

-------
air  system  instead  of  a mechanical air pump if the 40 percent AQL
were  retained.    The  actual  cost differential between  these two
systems  is  ($27-$4)=$23.9/   The 08Y2A family  represents  about  4
percent  of  all LDT  sales  so on  a per vehicle basis  the  cost is
about §0.92 per engine.

     Most of the NOx reductions  required by the more stringent AQL
could  be gained  through  changes  in EGR  or  engine calibrations.
However,  the EPA  technical staff expects  that the required reduc-
tions can be gained  through the  use  of the EEC  systems thus elimi-
nating  the  need  for  fuel  consuming engine  or  EGR calibrations.
The diesel  light-duty truck family produced by GM will require the
addition of EGR to meet  the NOx  targets.  This EGR system would be
the same  as  that  used  on the light-duty diesel passenger cars and
cost between $8 and $15  per vehicle.  The EPA  technical staff will
be conservative and  use the higher  cost  or  about $15 per engine.
On a per LDT basis this is  only  $.60  per engine.ll/

     The difference between the  40 and  10 percent AQL HC emission
targets  is  so  small  that it  would probably not cause any substan-
tial  change  in catalytic  converter  volume  or loading.   The  dif-
ference  in the CO target levels  is relatively  larger, and it might
be argued that  some of  the  catalyst volume  or  loading cost could be
saved with  the  40 percent  AQL.    The EPA  technical staff believes
that  the manufacturers would  probably  use  a  slightly  lighter
catalyst loading  and not expend much  effort  in catalyst  size
reduction.  The EPA technical  staff knows  of no formula or rules of
thumb which  relate noble  metal   loading  and  emissions reductions
explicitly.   It  seems  reasonable  that,  at most, only 0.1  to 0.2
grams  of noble metal  could  be  saved  in the  catalyst.   If one
assumes  that this metal  is Platinum  ,  the cost of 0.1 grams would
be about  $1.88.   Thus  lacking  any other input this  cost  will be
used for the gasoline-powered  light-duty trucks.

     Electronic engine controls  will probably be  necessary to aid
in the reduction of cold start emissions.   The EPA technical staff
has no  doubt  that  EEC  will be  used  regardless of the AQL because
there  are so many  benefits related to the  use  of EEC that the
manufacturers would probably  implement  these controls  for the
marketing and fuel economy benefits alone.  One other side benefit
of EEC  is to allow  the  manufacturers  to  optimize catalyst volume
and  loadings  to achieve the  greatest emission reductions  at the
lowest cost.

     4.   Recommendations

     The final  cost figures used to compute the economic  impact of
these regulations  should be reevaluated based on the manufacturers'
comments.

-------
                            References

J7   This $5-$10 estimate was  taken  from  the  R&D costs for similar
     component  shown  in EPA report  460/3-78-002,  Cost Estimations
     for  Emission  Control  Related  Components/Systems  and  Cost
     Methodology Description,  Leroy  H. Lindgren,  Rath and Strong,
     Inc., March 1978.

_2/   Based  on data   gathered  from  EPA's  Certification Data.

_3_/   See Chapter VII of the Regulatory Analysis which  supports this
     rulemaking.

_4/   Regulatory  Analysis,  Light-Duty Diesel  Particulate  Regula-
     tions, OMSAPC, EPA, February 1980.

5J   EPA memo, Light-Duty Vehicle Certification Cost,  Daniel Hardin
     to  E.J.   Brune,  D.M.  Kimball,   and  J.M.  Marzen,  March  1975.

6/   Based on  CPI data received from  the Bureau of Labor Statistic:
     1976 -  4.8 percent,  1977 - 6.8  percent,  1978  - 9.0 percent,
     1979 -  13.3 percent.   Use of  these  percentages is very con-
     servative.

7/   This catalyst  is 52 cubic inches and  is  loaded with 1.2 g of
~    Pt and Pd  in an  11:1 rat io.

8/   Sames reference  as  footnote  one.  The values on  page 301 were
     adjusted  by an  inflation  rate  of 26  percent over the three-
     year period,  the overhead/profit rate used was  29 percent and
     costs were estimated at  production  volumes of  8 and 16  mil-
     lion.   Thus,  ECUs  are  estimated to  cost  between $34-$47 and
     sensors  between  $10 and  $13  yielding a range  of $44-$60 for
     the simple  system planned.

9/   Same reference as footnote one.

IO/  Based on  Caterpillar Tractor Company's comment to the 1983 and
     Later  Model Year  Heavy-Duty Engine  Gaseous  Emission Regula-
     tions.          |

ll/  Assumes  this  engine  family,  or one  similar,  comprises  one-
     third of the light-duty  diesel  trucks sold, or  4 percent of
     all LDT  sales.

12/  Cost  Estimations  for  Emission  Control   Related Components/
     Systems  and Cost Methodology Description,  Leroy H.  Lindgren,
     Rath & Strong, Inc, March  1978.
                              -71

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13/  Abbreviations  used in this analysis:   PLS  - pulse air injec-
     tion;  M - monolithic  oxidation  catalyst;  P - pelleted oxida-
     tion catalyst.
                             7Z

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G.   Issue:   Technological Feasibility

     1.    Summary of the Issue

     EPA's proposed HC and CO standards  represent a reduction of 90
percent  in the emission  levels  of  uncontrolled baseline  light-duty
trucks.    This  chapter explores whether  these standards are tech-
nologically achievable within the  context of  revised certification
and auditing requirements and existing NOx  and particulate control
requirements.

     2.    Summary of the Comments

     Nearly  all  of the  commenters  agreed  on the following point:
The proposed HC and CO emission  levels are  achievable provided that
the existing  certification  provisions and  the  current 40 percent
SEA Acceptable  Quality Level  (AQL) are  left  unchanged.   Most
commenters argued, on  the  other hand, that in the presence of the
new useful life  provisions  and an AQL  of   10 percent, meeting the
standards will be difficult or even impossible.

     Several manufacturers  provided  estimates of  how they expect
the revised useful  life and/or  10  percent AQL requirements to
affect their ability  to  meet the  standards.  These estimates were
presented in  two different  ways.    The  first approach was to "ad-
just" the  standards  upward  to  a   level  which allegedly takes the
revised useful  life  and the  10 percent  AQL into account.  In the
second  approach,  the  anticipated design targets were shifted
downward in  such a way as to accommodate the new provisions.  The
following paragraphs present the industry estimates.

     General Motors (GM),  International  (IHC), and Volkswagen . (VW)
all offered  increased standards which  incorporate  the effects of
the 10 percent AQL (IHC  presented  the numbers upon request by EPA,
but opposes the 10  percent  AQL  and any  such adjustment of the
standard).  The  estimated levels follow:

                    HC g/mi        CO g/mi

     AMC            (1.6             20.0
     GM              1.4             20.0
     IHC             1.1             17.1
     VW              1.0             15.0
     (Standards)    (0.8)           (10)

     Toyota, GM, and  IHC presented estimated design target levels
which would result from a 10 percent AQL.  (GM's  targets need to be
divided by the deterioration factors in order to  be exactly compar-
able to  the  others.)   Additionally,  Toyota  estimated  the  combined
effect of a  full-life useful life  (they used 100,000  miles) along
with a 10 percent AQL.  In some  cases, the  targets corresponding to
the current  NOx standard  (2.3  g/mile)   are  included.   All of the
estimates appear below:

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                               HC
                              (g/mi)
 CO
(g/mi)
 NOx
(g/mi)
Toyota (10% AQL, 50,000-      .405         4.19      1.50
       mile U.L.)
       (40% AQL, 50,000-      .462         4.86      1.65
       mile U.L.)
       (10% AQL, 100,000-     .314         2.92      1.36
       mile U.L.)

GM     (10% AQL, 50,000-       .482/DF     5.50/DF
       mile U.L.)
       (40% AQL, 50,000-       .712/DF     8.84/DF
       mile U.L.)

IHC    (40% AQL, 50,000-       .53         7.69
       mile  U.L.)
       (40% AQL, 130,000-      .34         5.49
       mile  U.L.)
       (10% AQL, 130,000-      .26         3.2
       mile  U.L.)

AMC    (10% AQL, 50,000-       .021        2.5       0.9
       (mile U.L.)
       (40% AQL, 50,000-      0.42         5.0       1.8
       (mile U.L.)

     Chrysler expected  an  18.5  percent  increase  in the stringency
of the standards to  accompany  a 10  percent  AQL,  although no quan-
titative support  was provided.   Similarly,  AMC stated  that  the
target emission  levels   under  a 10  percent AQL  constraint  would
approach those  of  1983  light-duty  vehicles,  which, they  add,  is
"clearly not the intent  of  Congress."

     The interaction of the  existing  LDT NOx  and  particulate
standards with  the  standards  proposed in this rulemaking  was  the
subject  of comment,  particularly  from current and  prospective
diesel manufacturers.  During the comment period  for this proposed
rule,  a  0.2 g/mile  particulate standard had been proposed  for
light-duty  trucks in  a  separate rulemaking.  Since then,  a final
standard of  0.26 g/mile has been promulgated.   Thus,  it was with
respect  to  the  lower,  proposed standard  that  the comments  were
made.  The  current NOx standard is 2.3 g/mi.

     AMC claimed that if a 10  percent AQL  is  instituted,  the  2.3
g/mi NOx standard would  probably need to be relaxed if they are to
avoid  a  shift to three-way catalyst systems.   With respect /to
diesel-powered  light-duty trucks,  Cummins stressed the  inter-
dependency  between NOx and  particulate control (e.g., increased EGR
for  NOx reduction   can increase  particulate   emissions).   And
several manufacturers producing or considering producing light-duty
diesel trucks expressed  strong concern  that the  proposed particu-
late standard will be impossible to achieve with  known technology.

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Chrysler,  GM, and  AMC all  claimed that  a  0.2 g/mi particulate
requirement  would  probably  present  an  insurmountable  obstacle.

     Some  of the  commenters  offered  their assessment of  what
approach they  would pursue  in  trying  to meet  the  proposed stan-
dards.  General Motors  presented  the most complete  scenario.   The
following hardware  changes  and  improvements  are described as GM's
"best effort," based on their California experience.   (The proposed
standards  are  equivalent,  they say,  to California's 1980 50,000-
mile standards.)

     GM expects to  have  to  add  air  injection to their 5.0-, 5.7-,
and 6.6-liter engines;  the pulse-air system on the 4.1-liter engine
will  be replaced  with an air  pump.   Regarding the catalyst, a
heavier noble  metal loading, special  converter shell,  and struc-
tural improvements  will  be  required at  a minimum  for the sake of
increased durability.  Finally, GM  anticipates  that engine modifi-
cations to reduce  oil  consumption will  be  necessary.   Three-way
closed-loop systems are not  being  contemplated.

     Chrysler, however,  does  expect that they would use three-way
systems to  achieve  the  design  target  emission  levels.   However,
they  state  that   in the  absence  of a  full-life useful  life they
would use  a small  22in^ start  catalyst  with a 40  g/ft^ platinum
loading in  addition to  their main catalyst.   AMC as well suspects
that three-way catalyst  systems will be required for them to meet
the current NOx standard if the  proposed HC and  CO standards plus a.
10 percent AQL are implemented.  Volkswagen also  believes that a 10
percent AQL  would  require them to  use  three-way systems.   In the
presence of  a 40  percent  AQL,  however,  they would  expect  to use
only an oxidation catalyst and EGR.   VW would like to  avoid the use
of an  air  pump because  intermittent NOx reduction,  they say,  can
occur  in  a catalyst during  portions  of the  driving cycle.   If
additional air injection is  required to  meet the HC and CO stan-
dards, this NOx reduction will be  lost  and the current NOx standard
will be difficult to achieve.

     IHC  states  that  emission  levels  as low  as  their estimated
design  targets have been seen,  but they doubt that they could
consistently  reach  such  levels  in certification.    This company
claims their ability to comply with the regulations  is dependent to
a large degree on  the performance of outside vendors, which supply
much of IHC's hardware.   By having to depend  on  other  companies for
technological improvements  in their  hardware and  systems—and
perhaps for  some engines as  well—IHC  feels they  have  a reduced
ability to define their technological feasibility.

     3.   Analysis of the Comments

     The general approach of this section will be twofold.  First,
we will compare  the 1980 California certification emission levels
of current light-duty trucks  with  EPA estimated  target levels.  Our
targets are  based  on those  offered  by the industry in conjunction

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with our own analysis.   Second,  we will  investigate the achievabil-
ity  of these target  levels by 1980  engine  families and  what
control strategies we would expect  to  be necessary.   By following
this approach we  will  be able  to treat the comments  in a general
way rather than engage  in a comment-by-comment rebuttal.

     The  detailed  EPA  staff  analysis  which resulted  in  the  pro-
jected emission target  levels  is presented in  Chapter  VII  of the
Regulatory Analysis  document  titled,  "Cost Effectiveness."   In-
dustry data  about  emission  variability were combined  with antici-
pated deterioration  factors  to  arrive  at  projected  target  levels
which reflect full-life useful life requirements in the context of
a 10 percent  AQL.   The  reader is encouraged to consult this anal-
ysis, which in effect  constitutes much of our  response  to the
comments  which  concerned  emission  variability and  effects  of  a
full-life useful  life  and an  AQL of  10 percent on low-mileage
emission target  levels.

     a.    Gasoline-Powered Light-Duty Trucks

     Our  analysis of current  emission performance will  center
around  engine families certified  for California (or 50-state)
sales.    Since California's 1980  LOT emission  standards  are  con-
siderably tighter  than  the  1980 Federal standards and  are  in the
same range as the  1983  standards  proposed  here,*  one  would  expect
that California-certified engines  would  offer some insight into the
emission control strategies required  to meet  EPA's proposed stan-
dards.

     There is  one  reason  for  caution  when one makes comparisons
to California  vehicles.   Manufacturers have  warned  that in  com-
plying with California  standards they have  seen a  loss in the fuel
economy of their vehicles.   However,  as we discuss in  Issue  L of
this document,  "Fuel Economy,"  the  California  control approaches
amounted  in  most  cases  to "quick  fix" modifications  of  Federal
vehicles—modifications   that  have  stressed  easy  compliance  over
fuel-economy considerations.  Thus,  from control  technology stan-
dard  standpoint,  an analysis  using  1980 California trucks  is
compromised by the  fact  that  manufacturers  will most  likely begin
to emphasize control systems which minimize  fuel economy for  future
systems.

     Despite this  drawback we believe that a look at the California
control systems  and emission  levels  will  be  helpful.   Emission
rates for California vehicles  indicate  what is readily attainable
using  current catalyst  systems.  By placing side-by-side  the
California numbers and  the anticipated Federal  targets,  we will be
able to clarify at least generally where the feasibility problems
lie and how compelling they  seem to  be.
*     1980 California LDT standards range from .41-.9 g/mi for HC,
9-17 g/mi  for  CO,  and 1.0-2.3 g/mi  for  NOx,  depending on vehicle
weight and (for NOx)  type of  certification.  Federal 1980 standards
for LDTs are 1.7,  18, and 2.3 g/mi  for HC, CO, and NOx.

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     The 4,000-mile  emission  levels for the  1980  LOT engine fam-
ilies that were certified either for California only or for all 50
states are presented  in  Table  G-l.   These values are "undeterior-
ated,"  that  is,  they have not  been multiplied  by deterioration
factors, the process  which  would yield the certification emission
levels.   As they are, the numbers represent the actual low-mileage
emission test results  for the  certification fleet (California
plus 50-State).

     But the question arises as  to  whether this sample, consisting
solely of  California  engines,  is representative  of the entire LDT
fleet.  To a large degree it is  representative, because only a few
1980  federal-only trucks  have engines  which were not  sold  in
California trucks.   These are not exceptional  polluters, so conclu-
sions about  emissions feasibility  drawn  from the California data
can  be  reasonably extrapolated  to the  LDT fleet  as a whole.

     The numbers which we will compare with those of Table G-l are
the  staff's  projected 1983 emission  target  levels,  assuming that
the proposed regulations  are adopted:

     HC:   .49 g/mi
     CO:   5.5 g/mi
     NOx:  1.4 g/mi

It  is worthwhile  to  stress again  that these  target  levels  (from
Chapter  VII of  the  Regulatory  Analysis)  are  computed on the basis
of actual LDT  emission variability  and  under  the assumptions of a
full-life useful life and a  10  percent AQL.

     As  one  studies  the  data  of Table  G-l,  a demarcation quickly
appears  between the  emission  levels of  the smaller, generally
4-cylinder imported vehicles  and the  levels  of  the domestic
trucks.    The  foreign vehicles   show  considerably  better  emission
performance;  in  fact, none of  the  29  test vehicles  exceeded  the
estimated HC target,  only two  exceeded  the CO target and 5 met or
exceeded the NOx target  (just  one of these actually exceeded it).
Because  the  domestic  and imported  trucks  demonstrate such marked
differences in emission performance, we will  treat them separately
in our  discussion!   It  seems reasonable to concentrate on  the
American manufacturers as presenting the most  difficult feasiblity
problems.

     It  is clear  from Table G-l  that GM,  Chrysler,  IHC,  AMC,  and
Ford will  have to do development work above  and  beyond  what  was
necessary for 1980 California certification in order to reach EPA's
estimated targets.   Effort  will  need  to be  focused  primarily  on
improvements  in CO and NOx.  Hydrocarbon control is much less of a
problem, and control  of CO will  generally improve HC simultaneous-
ly.  Nine  of  the  44 domestic  test  vehicles (20 percent) are above
the HC target, but only 3 exceed the target by more than 0.1 g/mi.

     Carbon monoxide  levels as  recorded  in Table G-l  are higher
than the  targets  in  19  American  test vehicles,  and  most  of those

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                                 Table G-l
                   1980 California Certification Results
Manufacturer
AMC
Chrysler
Ford
                              Engine Family
                            (Displacement, CID)

                                 HT-3V1
                                   (304)

                                 NT-3A1
                                   (360)

                                 CT-4W1
                                   (258)
                                 BT-6C1
                                  (151)

                              OTA-225-1-BXP
                                  (225)
                             OTA-318/360-4BCP
                                (318/360)
                             OTA-318/360-4BFP
                                (318/360)
                                 4.9 NA \J
                                  (300)

                                 4.9 ND
                                  (300)
                                 5.0 NB
                                   (302)
                                                     4K-Mile Emissions  (g/mi)
                                 5.0 NG
                                   (302)
HC
.38
.28
.59
.57
.43
.40
.28
.18
.18
.30
.45
.22
.22
.44
.33
.40
.37
.27
.49
.44
.23
.17
.24
.36
.41
.59
.42
.70
.40
.31
.35
.35
CO
2.9
2.8
9.9
9.1
7.3
4.4
3.8
2.5
1.9
3.7
5.2
1.8
7.0
8.3
5.6
7.0
8.8
5.8
4,2
5.2
2.1
5.7
6.2
2.4
2.3
4.8
4.2
9.5
6.7
1.6
2.1
2.0
NOx
0.92
1.5
2.0
1.8
1.0
1.4
1.5
1.3
1.2
1.7
1.4
1.3
1.2
1.4
1.8
1.9
1.7
1.7
1.6
1.3
1.9
1.7
1.6
1.5
1.5 11
1.6 I/
1.4
1.5
1.1
i i
1 1>4
( 1.4
1.4

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                             Table G-l (Cont'd)




                   1980 California Certification Results
Manufacturer
GM
IHC
 Isuzu
 Nissan
 Mitsubishi
 Toyo Kogyo
Engine Family
(Displacement, CID)
5.8M/6.6NA
(351/400)


5.8 WNG
(351)
08F2A
(250)
08K4AA
(350)
V-304
(304)
V-345
(345)
4-196
(196)
A1TC
(111)



TL20C
(119)


GT5-C
(121.8)

,
OMAT
(120)
4K-Mile
HC
.39
.56
.20
.34
.33
.39
.43

.30
.41
.64

.77

.55

.26
.23
.23
.23
.22
.26
.24
.18
.14
.26
.19
.26
.20
.24

Emissions
CO
2.8
6.1
2.4
4.5
13.8
9.2
8.7

7.3
5.2
5.0

6.7

8.9

4.7
2.0
2.7
2.7
4.3
3.0
2.2
2.6
2.6
3.8
2.5
3.5
3.2
-2.4

(g/mi)
NOx
1.9 I/
1.5 I/
1.3
2.0 if
.98
1.5
1.4

1.0
1.5
1.3

2.0

1.7

1.3 I/
1.0
1.3
1.3 I/
.98
1.0
1.0
1.1
1.4
1.2
1.1
1.1
1.2
1.1


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                             Table G-l (Cont'd)




                   1980 California Certification Results
Engine Family
Manufacturer (Displacement, CID)
OWBT
(140)

Toyota 2F(C)
(257)
20R(TC)
(133.6)



VW 37PC
(97)
37PF
(97)
11

4K-Mile
HC
.24
.23
.25
.18
.20
.15
.12
.20
.16
.16
.16

.16

.19
.28
Emissions
CO
2
2
2
3
3
1
2
2
1
4
2

2

3
7
.5
.6
.8
.3
.0
.9
.3
.2
.9
.9
.0

.0

.8
.6
(g/mi)
NOx
1
1
1
1
1
1

1
1
1
1

1


1
.2
.2
.1
.2
.5
.4
.90
.0
.1
.2
.4

.4

.70
.1


11






I/






                                   12                  .28     7.6    1.1
I/   50-state certification.

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miss the target significantly (their average  emission  level is some
40  percent  over  the  target).    The 19  vehicles  represent  eleven
engine families.

     Completing  the  picture of  current  emission  control perfor-
mance, we find  that NOx seems  to present  the most difficult obsta-
cle to compliance with  the  proposed regulations.   Fully 32 of the
44 American vehicles  in Table  G-l,  representing all but two Cali-
fornia and 50-state engine families, meet or exceed the NOx target
(24 vehicles actually exceed it).   The  average  emission  level is 12
percent above the target; 5  vehicles are  29  percent or  more above.

     It  is  plain  that the  level  of  effort  which  the  American
manufacturers applied to meeting  the 1980 California standards will
not be sufficient to comply with  these  1983  regulations.  We cannot
agree, however,  with the comments  which argue that  the  task EPA
places before  the manufacturers  with this rulemaking  will only be
accomplished with new technology, high  cost, and major  compromises
in  fuel  economy,  if it can  be accomplished at all.   On the con-
trary, we find abundant  reason  to believe that—even in  the context
of a  full-life  useful  life and a 10  percent AQL—the  proposed
standards are  achievable  by all LDT manufacturers,  for  the most
part  with  current control  systems.  The next paragraphs support
this conclusion.

     In order  to  reduce  the HC  and CO emissions of  their federal
vehicles to California  levels  the  manufacturers have  for the most
part  relied on  improved catalyst efficiency and/or  additional
auxiliary air  injection.   Some have also introduced  small "start"
catalysts or  calibration  changes   to  improve  cold-start emission
performance.    The  cold  start  controls  present  special  problems
which we will  cover  shortly.   In general, though, we believe that
manufacturers  will  again  pursue, to a large extent,  catalyst
improvements and increased air for  their  1983  trucks,  just as they
did for California trucks in 1980.   Light-duty truck  catalysts are
an especially  fertile  area for emission  improvements, as the next
paragraphs demonstrate.

     Increasing the  internal volume and/or the noble  metal loading
of catalysts can  serve  two  crucial functions.   The first of these
is  the improvement of catalyst  efficiency,  as  defined  as  the
percent reduction in mass  exhaust  emissions available  through use
of the catalyst.  Increased  catalyst volume  implies that a greater
surface area of substrate material  is exposed  to the  exhaust flow,
improving the  opportunities  for   pollutant molecules  to  react.
Independent of  but related  to  converter sizing is the  quantity of
noble metals which are  applied to   the  substrate surface.   An atom
or a  group  of  atoms  forms  an active catalyst  site, and the amount
of reaction that can take  place is  dependent  on the  number of these
sites  that  are  exposed  to  the  exhaust  flow.    Although  there  is
obviously a limit, a general rule  is that the  greater the catalyst
loading,  the  greater can  be the  HC and CO emission  reductions.

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     In  addition  to  improving  the  conversion  efficiency,  increased
converter volume  and noble metal loading make the catalyst and its
operation more  durable.   This  is an obvious advantage in light of
the  proposed  extension  of light-duty truck  useful life.   The
durability of the converter structure—i.e.,  the physical  integrity
of the  substrate—is  improved  because  the greater mass and volume
make  it  less   likely  that  critical  temperatures  will ever be
reached  (1700°F for gamma  alumina  substrates).   The progressive
loss of surface  area  associated with  occasional high-temperature
excursions, and hence  the  loss of active sites and efficiency, is
thus minimized.   An  additional advantage is  gained  by  increased
noble metal loading in that more active  sites are initially avail-
able.   Thus,  even if a  number of  sites are  rendered  inactive
through  the life  of  the  vehicle by lead or phosphorous poisoning,
loss of substrate surface area,  or  agglomeration (catalyst  atoms
migrating  toward  each  other,  effectively reducing the  number of
sites),  a significant number will remain available.  In these ways
converter sizing and  loading can act  to extend the functional
lifetime of the  catalyst.  While both of  these approaches  are
clearly available  to the  manufacturers,  we expect  increased loading
to be  the prevalent  choice since manufacturers will probably wish
to limit the number  of  catalyst  canister  sizes that  they  make.

     Putting aside  for  the moment  the  improvements  in catalyst
durability, we believe  that  the additional  HC and CO control
available  through more heavily  loaded  (or  larger)  catalysts will
easily  be  sufficient   to  meet  the proposed  HC  and  CO standards.
As is  often the  case, EPA is  not able to  quantitatively support
this  statement  because  actual  data  from LOT's  equipped  with
prototype 1983  catalysts  are obviously  not yet  available.  However,
one  finds  that current  catalysts—even  on  California trucks—are
for the most part much  more  lightly loaded than what  we  would
expect   to be required  to  comply with these  regulations.   Economic
pressures have  clearly encouraged the use of the least  expensive
systems  necessary to meet the  California standards.  Coupling this
observation with  the  Agency's accumulated  knowledge  of catalyst
technology, we  conclude that a  considerable margin for improvement
in catalyst efficiency  exists  in most cases.

     In  some  instances,   such  catalyst  improvements  will require
additional  air  injection.   Most  current families  of light-duty
trucks   are  equipped with air  pumps,  which add  air  to the exhaust
stream  in  order  to  assure the  presence of  sufficient  oxygen to
maximize oxidation  in  the catalyst.    A  few  truck  families  use  a
modulated  "pulse-air"  system,   and  a  few more have  no   auxiliary
air.    We expect  that  most trucks will  have  to incorporate  addi-
tional   air  injection   in  order to make full use of  the improved
catalysts, particularly American-made vehicles with larger engines;
if there is presently none, an air pump may need  to be added.  The
implications which increased use of air injection hold  for LDT fuel
economy are addressed  under Issue L,  "Fuel Economy."

     GM will perhaps be most affected by a need for additional air
injection.  We  agree that  their  4.1-liter engines, which  currently

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use the  "pulse-air"  system,  will need air  pumps.   While a large-
selling  50-state  family  using  a 5.7-liter engine (08K4AA) already
uses  air injection  in California applications,  GM is  probably
correct  in predicting that auxiliary air will be necessary for the
remainder of  the 5. 7L  engines as well  as for  the 5.0L  engine
family.

     While we have been  able to  project that catalyst improvements
and increased air injection  can  themselves  bring many current
trucks into  compliance  with  the 1983 HC  and  CO requirements, the
actual picture will be somewhat different.  This is because we are
anticipating a major shift by  1983 to the use  of electronic engine
controls  (EECs)  as a part of  LDT  emission  control  packages.   The
introduction of  EECs,  already  popular  in  passenger  cars,  should
occur at  least partially as a  result of inherent conflicts between
cold-start emission  control  and fuel economy.   Both conventional
ways of  reducing  HC and  CO prior to catalyst light-off suffer from
drawbacks.   Small, rapid light-off catalysts  are subject to quick
deterioration due to their proximity to  the engine.   The alterna-
tive approach,  adjusting the timing to speed up the heating of the
catalyst, causes  a  fuel economy penalty  all  during  the  vehicle's
operation (these  calibration changes are  the  cause  of much of the
loss  in  fuel economy  experienced in the  1980 California fleet
compared  to  the  Federal  fleet).   EECs  offer  a way  of varying the
timing,  returning the  engine  to a more fuel-efficient calibration
after the catalyst begins  to work.  Thus, while working  to reduce
th  heavily-weighted  cold-start portion of  a vehicle's  emissions,
EECs  can simultaneously avoid  a  loss  in fuel economy  (Issue  L,
"Fuel Economy"  explores this  issue  further).

     Although meeting  the  existing NOx standard of  2.3  g/mi will
become more difficult with the  implementation of the proposed rule,
compliance  is within the  reach  of  all domestic  (and  foreign)
manufacturers using  current  technology  NOx control.   That current
technology is exhaust gas recirculation  (EGR),  a system found today
on nearly all light-duty trucks.  An  increased  flow of recycled gas
will  probably  be required for most  U.S.-made  trucks,  though this
increase should not go  far  beyond what has  been required for
California compliance.    Table  G-l  demonstrates  that while Califor-
nia systems  often fall  short of the EPA  target, few of the levels
are grossly above  that  target.  Our  conclusion,  is that minor
increases in EGR rates  or  none  at  all will  be  sufficient  for
most engine  families to  remain within  the existing  2.3 g/mi stan-
dard.   A small  number of engine families,  concentrated primarily in
the larger  CID  range,  may require  a  significant amount  of  EGR.
This expectation is  tempered  by the fact that a shift away from the
heavier engines will  probably occur in the next few years, a topic
that is taken up in detail in Chapter V  of the  Regulatory  Analysis.
As  a  final  note, EGR has  negative implications for  fuel economy,
but modulation with an  EEC helps  to minimize this.  We address this
issue in section L  of this document,  "Fuel  Economy" and conclude
that  on  a fleet-wide basis,  the net  fuel economy loss  due to NOx
control will be minimal.

-------
     Manufacturers may opt in  some  of  these  latter cases  to apply
three-way catalyst/feedback carburetor technology, but this should
be a rare occurence; we doubt  strongly that these regulations will
require a move to three—way technology for any manufacturer.  This
doubt  is based  on two  facts.   First,  NOx control efforts  on
California trucks  have  been aimed  at  meeting  relatively  high
standards  (in  most  cases, 2.0  or  2.3 g/mi,  depending  on whether
deterioration is calculated  on  the  basis of  50,000 or  100,000
miles).   This  makes it  unlikely  that many of  these  engines  have
reached  the  limits  of NOx reduction  through  EGR.  Second,  it  is
generally in the  small number  of  engine  families  which  exceed 340
CID in  size  that  the more difficult NOx  problems  seem  to be con-
centrated.   Again we point  to the anticipated downward  shift  in
engine size,  which will act to  reduce  the  number of engine families
with higher NOx emissions.   Our conclusion is  that the degree  of
NOx control necessary to  meet  these regulations,  barring possible
exceptional  cases,  is available  to  all manufacturers  through
increased EGR.

     We have primarily directed the  foregoing  discussions  of HC,
CO,  and NOx  feasibility  at  American-manufactured  engines.   The
basic strategies  for meeting  the proposed  standards, i.e., catalyst
improvements,  more air injection,  additional  EGR,  and EECs, apply
as well to the manufacturers of  imported LDTs.  However,  the
already lower emissions  of the imports demonstrate that  the neces-
sary degree  of improvement  in the existing control systems  is
small;  in many instances  no improvement over California technology
appears to be necessary  at all to achieve EPA's estimated targets.
Slight  improvements  in catalyst conversion efficiency  (as discussed
earlier) may be desired  for  lower  CO  for some  families,  but this
approach is probably not  necessary.  Thus, the need for air injec-
tion (or additional air injection)  will not be  widespread.   (This
would mean  that  VW will  probably  not have  to sacrifice  the NOx
control they get  in the  absence of an air  pump).   Regarding NOx,
again very little is required,  but  a  slight  increase  in EGR above
that seen  in  California  certification may  be  necessary  in  some
cases.    In any event, compliance  with the regulations by  all  of
the  foreign manufacturers  seems  assured with  California-type
control  systems,  perhaps  upgraded  with  electronic  controls.

     There was  a  great  deal  of comment  that indicated  that  the
effect  of  a  10 percent AQL  and a  full-life  useful life  would  be
greater than what we have  concluded in -this  analysis.  As a check
on  the  reasonableness  of  our  feasibility analysis,   we have  per-
formed  a  separate analysis which uses actual  1980 California LDT
production audit  data.   (This  work has been  placed in  the public
docket  and is titled "Analysis of California  2% Audit Data.")
We have  applied the  estimated full-life  deterioration factors*  to
the audit  emission data  and  calculated   the  rate at which these
vehicles fail to meet  the  proposed  Federal standards.  The analysis
used emission  data  from  7 tests on IH vehicles,  81 on Chryslers,
and 262  on Fords, and 263  on GMs, totaling  613  tests.   The re-
     1.4 for HC, 1.3 for CO,  and  1.04  for NOx.

-------
suiting failure of the proposed  standards occurred at a rate of 5.4
percent  for HC,  7.8 percent  for CO,  and 8.8  percent for  NOx.
Further,  if  one  exceptionally  failure-prone  Ford engine family  is
removed from the calculations,  the failure  rates drop to 5.0,  7.1,
and  4.4  percent  for HC, CO, and  NOx.   We can  conclude  that  with
absolutely no  effort toward meeting  the  proposed  regulations,  a
significant number of American made California LDTs already do and
they would quite easily pass a  10  percent AQL audit.  It would  seem
that our original analysis based on the target levels results  in a
conservative view of LDT feasibility.   This look at actual produc-
tion  performance  is  strongly  supportive  of  our  conclusions  that
compliance with these regulations  is achievable.

     A final  issue  relating  to  feasibility  deserves  discussion.
While  we  factored  into  our analysis  the  effects of  a full-life
useful life from  the standpoint  of  initial  zero-mile emission
requirements, we  have  not  yet discussed  the  feasibility  of  de-
signing emission  control  systems  which  actually  function  for the
120,000-odd-mile lifetime of  an LDT.   Since durability is not  a
major problem for air pumps and EGR systems,  the discussion should
focus on  the longevity of catalysts in  LDT  applications.

     In developing  a separate  argument, AMC  presented  data  for  4
catalyst-equipped light-duty vehicles.   The  data consist of peri-
odic emission results  extending out  to  100,000  miles.   (The  data
has  been plotted  in Figures G-l  through G-4).  While the  data
points are somewhat  scattered, there is  in three vehicles  a clear
pattern of linear deterioration  of HC,  CO,  and NOx emission deteri-
oration (or improvement  in the  case of  NOx).  This is what we would
expect to occur in a normally functioning catalyst; i.e., a gradual
loss of efficiency with  no evidence of  severe damage.  (One vehicle
seems to have suffered  engine  problems late  in its life — HC and
CO  emissions skyrocketed  yet  NOx went down.)   On those three
vehicles, the catalyst  was  still  functioning well—that is, there
had been  no abrupt failure—even after  100,000 miles of use.  It is
even more telling that  these long  catalyst  lives are  seen  on
1975-76 vehicles equipped with  early  technology automotive catalyst
systems.

     Further evidence of catalyst durability comes  from a recent
EPA  program in which 8 catalyst-equipped  cars with an  average
accumulated mileage of 104,480  miles were  emission  tested (as
reported   in  "Evaluation  of Restorative Maintenance  and Catalyst
Replacement on Exhaust Emissions  from Eight  Very High  Mileage
Passenger  Cars  in  St.  Louis," available  from  the  public docket
associated with  this  rulemaking).   The  vehicles were  tested  in  5
configurations:    in  an  as-received  condition,  after correction of
maladjustments,  after complete tune-up, with  the catalyst removed,
and  with  a. new catalyst.   An  upward  jump in HC and CO emissions
when  the  catalysts were  removed  demonstrates that  the catalysts
were clearly  still  functioning  even  at these  high mileages.
Further,  after maladjustments and  disablements were corrected and a
tune-up  performed,  half of the  vehicles were  able to meet  the

-------
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-------
federal emission  standards with their original catalyst — roughly
the'fraction  that  would be expected to have  met  the  standards  as
they  came  off the production  line  under  the  production practices
existing at the time  (designing for  the average vehicle to meet the
standard).

     Thus, evidence  clearly  exists  that  passenger  car catalysts,
while designed  to operate only 50,000 miles,  commonly last  twice
that  long.   The  light-duty  truck catalysts  that  we  expect  to  be
used  to  comply  with  these regulations  will be, as  discussed  ear-
lier, inherently  more  durable due  to sizing  and  loading improve-
ments.   It is  a reasonable conclusion, then,  that long-lived
catalyst technology will  be  available  for 1983 light-duty trucks.

     b.    Diesel-Powered Light-Duty  Trucks

     The issue of feasibility is very different for  diesels.   They
generally show low HC  and  CO emissions; but  because of the higher
combustion temperatures (as  compared  to gasoline engines) NOx
values tend to be higher.  In  addition,  one must be concerned with
particulate emissions, standards  for  which  have  recently  been
published  (Particulate  Regulation   for   Diesel-Fueled  Light-Duty
Vehicles  and Light-Duty  Trucks,   45 FR  14496,  March 5,  1980).

     As  a  basis  for  comparison,  we will  use the  same  estimated
low-mileage targets  that we  used  for  gasoline  LDT's.  This  is
because  emission variability  and  deterioration information  is
very  sparse for  diesel LDTs.   Since the HC  and  CO deterioration
factors  will on  the  average  be smaller for diesels,  the gasoline
truck targets will be  conservative  and will  provide an additional
"margin  of  safety"  in the  following  feasibility analysis.   NOx
deterioration, on the other hand, may be more rapid in diesels, and
it might  appear  that  the diesel NOx  target  should  be lower  to
compensate for this.   But tfre  1.4 target   is already a conservative
estimate because  of  the very high NOx variability  that  was  used.
We  feel  justified in  using the gasoline target for diesels  as
well.  For convenience  we repeat the targets (g/mi):   HC - 0.49,  CO
- 5.5, NOx - 1.4.

     We  have  collected  the 1980 certification data  for light-duty
diesel trucks  and for GM's diesel-equipped Oldsmobile passenger car
in  Table  G-2.  The  passenger  car  is  included since it uses  an
upgraded version of the same  basic engine  that  the GM trucks do and
was  tested  at  relatively high  inertia weights  (4,000,  4,500,  and
4,750 Ibs).   Its emission performance  should  reasonably represent
that of  a LOT  equipped  with that engine configuration.          !  '

     Carbon monoxide  values  are all well below  the  target.   HC
falls below the HC target in all but one  case.  The exception, the
GM  diesel  truck,  uses  an engine configuration different  than that
used  in  the  Oldsmobile,* probably  the  1979   configuration.   The
*    GM  used  different  injectors  and introduced EGR on  the  Olds-
mobile.

-------
                   Table  G-2

1980 Light-Duty Diesel  Certification Emission Data
    (Undeteriorated Gaseous Emissions, g/mile)

Manufacturer
GM LDT


GM LDV
(Oldsmobile)


IHC LDT

VW LDT

Engine Family
(Displacement, CID)
09J9Z
(350)

03J9ZG
(350)


SD-33T
(198)
DP
(90)
4K-Mile
HC
0.84
0.61
0.82
0.28
0.30
0.34
0.17
,,0.45
0.39
0.32

Emission
CO
2.0
1.9
2.0
1.2
1.1
1.1
1.2
2.2
1.6
0.90

(g/mi)
NOx
2.0
2.0
1.9
1.8
1.6
1.4
1.7
1.6
1.4
1.1


-------
passenger car  has had  to meet a  tight 0.41  g/mi  standard  in
1980 for the first time,  and its performance clearly indicates that
the  truck's  HC could  greatly  be reduced  by using the new  engine
configuration.  It appears, then, that there is nothing inherent  in
current diesel  LDT engines that  will prevent their meeting  EPA's
HC and CO targets.

     With respect  to NOx on the other hand,  additional development
work will be  required  of the  manufacturers  in some cases  in  order
to achieve the estimated  1.4 g/mi target.  This does not seem to  be
a large problem.  One finds in Table G-2 that, if we exclude  the  GM
truck, all current certification vehicles  lie in the  1.2-1.8  range
(in fact, the  VW  engine  falls well below  the targets  on  all  three
pollutants).   We  again make an exception  for  the  GM  LDT,  assuming
that the  cleaner  Oldsmobile LDV engine  will be used  in  the  truck
applications.  Focusing,  then,  on the  IH truck and the Oldsmobile,
an increased rate  of  EGR should provide the  degree of NOx control
necessary for the vehicles  to  reach  the vicinity of 1.4 g/mi.   This
is a  reasonable conclusion on  the  basis  of EPA's observation  of
diesel passenger cars, which indicates relatively  low  rates  of EGR
are currently used and hence, a range  of control remains  available
to manufacturers.

     The final  item  pertaining  to diesel  light-duty trucks  is the
question of  particulates.   The adoption of  full-life  useful  life
and a  10  percent  AQL  affects  the  difficulty of  meeting  particu-
late standards  as well  as HC,  CO,  and NOx.   However, the  staff
finds that this increased  difficulty  is  overcome by the relatively
less  stringent  NOx  standard  applicable to  light-duty trucks  in
comparison to light-duty  vehicles.

     The particulate standard of 0.6 g/mile which will be applic-
able for  1983  and 1984 was derived  so as to be  achievable  in the
context of a  1.0  to  1.5  g/mi light-duty vehicle NOx  standard (the
actual amount depending on  the outcome of NOx waiver requests).   By
comparison,  the light-duty  truck requirement of 2.3 g/mile is  quite
generous.   Where  EGR is  being used  to control  NOx, there  is  a
direct relationship between NOx and particulates  such  that  as NOx
goes up, particulates  go down.   The  following analysis shows that
the less  stringent 2.3 g/mi NOx standard  allows sufficient  flexi-
bility  to  meet the  0.6  g/mi  particulate standard for  light-duty
trucks at  a 10 percent  AQL  and full-life useful life.

     The Regulatory Analysis  for the  light-duty  diesel particulate
regulations  included some  data  which had been supplied by General
Motors in their May 1979 application  for waiver  from  the  1981-1984
NOx emission standards for  light-duty  diesel  engines.JY   This data
illustrates  the relationship  between changing particulate and NOx
emissions  for  3  GM  test  vehicles,  all in  the  4,500  Ib.  inertia
weight class.  This data will be used to characterize  the relative
amount  of  particulate/NOx  tradeoff  which could occur, all  other
things being the same.

-------
     In  analyzing  the  feasibility  of meeting  the 0.6  g/tni  par-
ticulate  standard,  the  staff  found  that  GM  would have  the  most
difficulty with the  standard ._2/  Therefore, although the amount of
tradeoff  may  vary between  manufacturers,  we believe  that  if the
available  flexibility  is sufficient  for  GM  it  will  also  be  suf-
ficient for other manufacturers.

     The  tradeoff  flexibilities  in  going from a NOx  level  of 2.3
g/mi  (the light-duty truck  standard)  to 1.5  g/mi  (the maximum
light-duty vehicle standard) amounts to  36 percent for car "A," 54
percent  for  car "B,"  and  52 percent  for  car "C."   That  is, all
other things being equal,  going  from 2.3 g/mile NOx to  1.5 g/mile
NOx  causes the  particulate emissions of these three engines to
increase  by  the given percentages.   Since,  for  the case at  hand,
all other things  are not  equal,  some  or all  of this  available
"cushion" will  get used  up.  Our desire  is to determine if indeed
this  available  "cushion"  is  sufficient  for  light-duty  trucks to
meet the same standard as light-duty'vehicles.

     There are three areas where  "cushion" is  needed.   First is the
increase  in  emissions associated with  increased  road load horse-
power and  inertia weight of light-duty trucks.  The staff analysis
for  the  light-duty  particulate  package  concluded  that  these in-
creases amount to approximately  20 percent.3/  Second, a "cushion"
to cover  the  added  full life useful  life requirements is needed.
Using a maximum deterioration rate of  i.l  for 50,000 milesj4/,  this
adds another 10 percent (to go from  50,000 miles  to 100,000 miles).
Lastly is  the  amount of "cushion" needed  to  go  from a 40 percent
AQL to a  10  percent  AQL.   This  can be estimated using the method-
ology  of  Chapter VII  of our  Regulatory Analysis  for this   rule-
making, once an  estimate of production variability is known.   The
staff  analysis  for  the  light-duty  particulate  package  determined
that  particulate  variability should  be  quite  lov.5j   Using the
relatively  low  variability  characteristic  of hydrocarbons  as an
estimate, the  data  in  Chapter VII of the  regulatory  analysis
indicates  an 8  percent "cushion" associated with changing the  AQL.
The  total "cushion" needed is  then  20 +  10  + 8 =  38  percent.

     The  required  "cushion" compares   very favorably to  that
available  from  the  three  test   vehicles.   Two  of those vehicles
(cars "B"  and "C")  exceed  this  requirement by a wide margin.   The
third, car "A",  also has an adequate  "cushion."   In calculating the
36 percent available,  no allowance was made  for the fact that the
actual NOx levels  would be  somewhat below,  rather  than  at the
standard.  It is in  the  nature of the  NOx/particulate  relationship
that  at  smaller NOx levels, the  amount  of  tradeoff increases.
Also, from the point of view of the needed amount of  'cushion', the
38 percent is an estimate of what should be the maximum need.  For
example,  the 20 percent change associated with inertia  and and road
load differences between light-duty vehicles and light-duty trucks
was a conservative estimate from data  showing an average change of
16-18 percent.   Therefore,  the staff  concludes that  the feasibility
analysis  associated  with  the light-duty  particulate regulations

-------
remains valid, even in the context of  a  10  percent AQL and a full
life useful life.

     In  1985,  we  expect  that  new NOx control  requirements  will
become  effective  for LDT's  and heavy-duty  engines.   Although
it  is  not necessary  to discuss the  effect  of such a  standard
on  LDT  diesels  (that  is a  topic for the NOx rulemaking itself),
it  is  germane to  look  at  how the current  2.3  g/mi  NOx standard
will  affect  light-duty diesel  trucks  if  it is retained  after
1985.   Again,  the light-duty diesel particulate final rulemaking
considered NOx in the  establishing of  the second-stage  (1985)
particulate standards,  0.20  g/mi  for  LDVs and  0.26  g/mi  for
LDTs.   The 30  percent  higher  standard  for trucks  is  the result
of  an  analysis  which  assumed  that  a stricter  NOx standard* would
indeed  be  implemented  in  1985,  removing the "safety margin"
which the  trucks  would  have previously enjoyed  (as  per  the  pre-
ceding paragraphs).  The  adjustment in the particulate standard was
made to  address just  such  a  situation.  In  the  absence  of a 1985
NOx  reduction,  there should  remain  something  of the  1983-84
margin.   Thus,  for the  post-1985 time  frame,  we see no  incon-
sistency between a 2.3 g/mi  NOx  standard and  a 0.26 g/mi partic-
ulate standard.

     c.    General  Responses

     IHC made a  comment  which  relates  to feasibility yet  is  not
technical  in nature—that vendor dependency  constrains  their
ability to  change  technology.   We recognize the special problems
associated with  relying  on outside  suppliers.   However,  in  this
particular case, we do not agree that  the resulting problems  need
be  severe.   For example, the required technological improvements
are relatively minor and  should not  in  themselves cause undue
delays in vendor deliveries.  Also, since  this is an industry-wide
action,  the vendors, too, should  be well  aware of the changes at a
very early stage.

     A general  overview  of  the  comments  and  our  response  in  the
area of  feasibility reveals  significant  disagreement  between  EPA
and the commenters regarding  the  effect that a 10 percent AQL will
have on  emission targets.   No commenter performed an  analysis
approaching EPA's in thoroughness.   We  are  confident  that  our
conclusions are based on sounder grounds than  those of  the  com-
menters.   For example, AMC was noted earlier as claiming that  the
target emission  levels  under  a  10 percent  AQL would approach those
of  light-duty vehicles.  However,  this position was  based  on
nothing more  than  an  "assumption"  that the 10  percent  AQL would
lead to target levels  that were  one-half of those for the current
*    They assumed  that  an LDT NOx standard comparable  in stringency
to  the  1.0 g/mi  LDV  standard  (1.0 g/mi  presumes  no further NOx
waivers beyond  1985)  would be enacted.   This  is  a  "worst case"
scenario,  since  the  1985 NOx standard is not likely to  be so
stringent.

-------
40 percent AQL.  .Our analysis  shows  that  this  is not true.  The HC
and CO targets for a  10  percent AQL are  92 percent and 86 percent
of those  for a 40 percent  AQL, respectively.   Targets used  by
individual  manufacturers may vary somewhat  from those we have
estimated, but  not  by  the amount claimed by AMC.

     It should  also be  recognized that the  delaying of  in-use
durability  requirements has  removed  one of  the complicating
factors and has thus  improved  the situation of  the manufacturers.

     4.   Recommendation

     The  staff concludes  that  no  technological  barriers  exist to
prevent compliance with  these  regulations by  all  light-duty truck
manufacturers.    We recommend   that  the  proposed standards  be  re-
tained .

-------
                             References

\J   Regulatory Analysis of  the  Light-Duty  Diesel Particulate
     Regulations for  1982 and Later  Model  Year Light-Duty Diesel
     Vehicles.  Figure IV-1.

_2/   Ibid, pg. 42.

_3/   Ibid, pg. 57.

4/   Ibid, pg. 36.

5/   Ibid, pg. 34.

-------
H.  Issue:  Selective Enforcement  Auditing

     In the July 12,  1979 NPRM, EPA proposed to revise the current
Selective Enforcement Auditing (SEA) program for light-duty trucks
(LDTs).   The  proposed  SEA replaces  the 40  percent Acceptable
Quality Level  (AQL)  currently  in  effect  with  a 10 percent AQL and
substitutes a  sequential sampling plan for the batch sampling plan
that  is  presently  in  Subpart  G.   There were  also  several  other
proposed changes to the current LDT  SEA program.

     The major  portion of  the LDT  manufacturers'  comments  on the
proposed LDT SEA concerned  the 10 percent  AQL; therefore, a large
part  of  this  summary and  analysis is dedicated to that  issue.
Comments on  other  aspects  of  the SEA  proposal  are addressed fol-
lowing the discussion of the 10 percent AQL.

Acceptable Quality Level

     1.  Summary of the Issue

     In brief,  this  issue  can  be  stated  as follows:   What Accept-
able Quality Level  (AQL)  should  be  promulgated in the final rule?
The AQL represents the percentage  of light-duty trucks (LDT) within
a  given  population which  will be allowed to  exceed  the emission
requirements.   The  Clean  Air Act  does not specify the precise AQL
to  be applied to  an  assembly-line  testing  program  like  SEA.

     A 10 percent AQL reflects  EPA's view that  the  statute requires
every  vehicle to be  warranted  to meet the  emission  standards
while allowing a 10 percent failure  rate  to account for measurement
error and inevitable quality aberrations.

     EPA promulgated an initial 40 percent AQL for its current SEA
program because at the  time the  SEA  regulation  went  into effect
(1976),  the industry was  building vehicles  and trucks to meet
previously established standards  on the average.  A 40 percent AQL
assures that,  for  a vehicle population  assumed  to have  a skewed-
normal distribution,  vehicles  within  this  population  will comply
with  standards on the  average.   In  order to  have brought  the
light-duty engine  families  into  compliance  with a 10 percent AQL,
manufacturers  at that  time  would  have  had  to add  additional emis-
sion control equipment  to  retain  their certificates of conformity.
EPA's  intent  in promulgating  an initial  40  percent AQL  for  its
current  SEA  program  was  to provide light-duty  vehicle  and truck
manufacturers  the  time and  flexibility  to bring  all  their motor
vehicles  into conformance with the  standards  on a reasonable
schedule.   This schedule  is to  parallel efforts  to  improve fuel
economy.

     In the  LDT Notice of  Proposed  Rulemaking (NPRM),  the Agency
proposed a 10  percent AQL as part of the total  compliance strategy
outlined in  the proposal.    EPA  indicated  that the 10 percent AQL

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could be met with costs not unreasonably burdensome to the manufac-
turers.  Comments on cost  associated with meeting  a  10 percent  AQL
were requested in the proposal.

     2.  Summary of the Comments

     All  the  manufacturers  and organizations  that  responded
to  the  NPRM  opposed  the  implementation  of a  10  percent AQL  for
SEA.  Most  of the comments concerned the legal, technological  and
economic reasons  why  a 10  percent AQL  should not be  promulgated.
Very little data were provided relating  to the actual technological
and  economic  considerations associated  with  meeting a  10  percent
AQL.

     All commenters made one or more  of  the  following major points:
the  10 percent AQL is  inconsistent with the  intent of  Congress  and
the  Clean  Air Act;  the 10  percent  AQL would  have  the  effect  of
lowering the standards  to a point where  the  emission  reductions  are
greater than the reduction mandated by Congress; the  10 percent  AQL
is  inconsistent  with  the  40  percent AQL used  in  the  light-duty
vehicle (LDV)  Selective Enforcement  Auditing  program;  and the  10
percent AQL  is not  feasible  due to testing  and  production  vari-
ability.  In  addition,  commenters gave various  other reasons  why a
10 percent AQL  should  not  be put into effect:   it is  inconsistent
with certification  requirements which  imply  "averaging"; it will
cause penalties  in  fuel economy; the air  quality  benefit of a  10
percent AQL  has  not. been  calculated;  and no  cost  estimates have
been made concerning the  increased costs,  in the  areas  of  produc-
tion testing,  emissions hardware, and  fuel consumption,  involved
with implementing a 10  percent AQL.

     Most manufacturers  stated that  due  to  the above  reasons  the
AQL  should be  revised  to  40 percent  in the final  rule.   Some gave
examples of a 40 percent AQL sampling plan that  EPA could adopt  for
the final rule.

     a.  Light-Duty Truck Manufacturers

     General Motors (GM)

     GM stated that it  is opposed to  a 10  percent AQL sampling plan
for SEA.  GM believes that Congress  intended,  in the  1977 Clean  Air
Act  Amendments,  that  production  vehicles meet  the  emission  stan-
dards on the average.

     In its  SEA discussion,  GM directed  most of  its arguments
towards supporting  the concept  of  averaging  for  production line
testing.   These arguments  included  statutory language;  the  Draft
Regulatory Analysis  discussion which GM  claims to  be based  on
averaging; ambient  air quality  considerations;  various  past Con-
gressional Committee reports  and  statements of  EPA Administrators;
consistency with  certification requirements; and  the  analysis  of
the baseline testing program.

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     GM also stated the emission design  targets necessitated by the
10 percent AQL would be below those justified in the environmental
and economic impact analysis.   GM provided an analysis based on its
1979  production  varability.    GM estimated  the  design  targets  as
.482/DF g/mile for HC and  5.50/DF g/mile for CO.  GM also submitted
an alternative  sampling  plan  which determines  compliance based  on
the mean  emissions  of  a  population.   GM advocates  the use of this
sampling  plan  because  it  incorporates the averaging concept which
GM believes is consistent  with the intent  of Congress.

     Ford Motor Company (Ford)

     Ford stated that it  opposed a 10  percent AQL sampling plan for
SEA.   Ford  believes that,  as  a matter of law and good engineering
practice,  a 10  percent  AQL  is  inappropriate  for  production-line
auditing.

     Ford  argued  that it  is not technically  feasible to  meet
a 10  percent AQL  and an averaging  concept is necessary for produc-
tion line testing.  Ford  submitted an  analysis of the design target
as a  function of  the  ratio  of  the standard deviation  to  the Low
Mileage Target.   The Low  Mileage Target equals  the emission stan-
dard  divided  by  the deterioration  factor.   On  the  basis  of this
analysis, Ford claims that it  would not  be technologically feasible
for it to comply with the 10 percent AQL.

     Ford also stated that the  10  percent AQL is inconsistent with
the  certification process  and the intent  of Congress.   Ford
developed an AQL sampling plan similar to the one proposed  by
EPA.  Ford's plan incorporated a 40 percent AQL.  It suggested that
this  plan be  adopted in the final  rule  because a 40 percent AQL is
consistent with  the requirements of  the Clean Air Act  and the
current SEA program.

     Chrylser Corporation (Chrysler)

     Chrysler commented  that  the 10  percent  AQL represents  a
"considerable  increase in  stringency" over  the  40  percent  AQL and
would result  in a greater than  90  percent reduction from baseline.
Chrysler estimated  that the 10  percent AQL would cause it to lower
its design  targets by  approximately 18 percent.   The estimate  is
based  on  an analysis  in  which   Chrysler assumed a  lognormal dis-
tribution  and stated  the  coefficient of variation  is   .2.   This
manufacturer  stated that  the  Clean Air  Act  does  not require every
vehicle to  meet  the emission  standards  throughout its useful life.
Rather, Chrysler  believed the  Act  "compels"  averaging  because  of
the  Section 202(a)(3)(A)(ii)  statement requiring reductions  "-   .
.from  the average  of  the actually measured  emissions.  .  ."   It
stated  that a 40  percent  AQL  was instituted for  the current SEA
program "to  avoid an unreasonable  economic impact on the in-
dustry."    Chrysler stated  that the  several  SEA program  were
evidence that the industry is  not advanced enough in its  production

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practices Co contend with a  10  percent AQL and that  the  10 percent
AQL was  therefore  unwarranted and unsubstantiated.   Chrysler also
stated that  in the  Regulatory Analysis EPA recognized the similar-
ity between  light-duty  vehicles and light-duty trucks;  therefore,
"It would make little sense  to attempt  to  extract different quality
levels from essentially identical types of vehicles."

     Chrysler  advocated adopting a  40  percent AQL because  of
economic  and technological  considerations  and  because  it  would
satisfy the Congressional intent of averaging.

     American Motors Corporation (AMC)

     AMC stated that it opposed a  10 percent AQL sampling plan for
SEA because it "would increase the stringency of the proposed
numerical standard  greatly  in excess  of  the  90  percent reduction
mandated by  Congress and  is inconsistent with  the Congressional
intent of averaging".

     AMC believes  that the functional  reliability of exhaust
emission components necessary to meet  a 10  percent AQL  is not
"practical and affordable"  in volume  production  of  vehicles.  AMC
stated that  the design  targets .necessary  for  it  to  reach the 1983
LDT standards with  a 10 percent AQL  sampling  plan  are  .21   g/mile
for HC and  2.5  g/mile  for CO.   AMC  estimated  that  the  design
targets necessary to comply  with  a 10  percent  AQL were  50 percent
lower than the design  targets necessary  to meet  a 40 percent AQL.
However, an  explaination  of how  this  figure  was derived was not
provided with the analysis.   AMC stated that a  10 percnet AQL would
have the effect  of  increasing the stringency of the NOx standard to
a  point  that would  require more  sophisticated  emissions control
technology (e.g. three-way catalyst).  AMC estimated that it would
cost  it  and its  vendors several  million dollars  to  assure a  10
percent AQL.

     International  Harvester Company (IHC)

     IHC opposes the 10  percent  AQL sampling  plan  for SEA because
it is claimed to be beyond the  statutory  authority provided  to EPA
and because it would allegedly cause an adverse economic burden on
the manufacturers.   IHC believed that Congress did not intend a 10
percent  AQL be  promulgated because  that AQL  imposes  emission
standards more stringent than those required by certification.  IHC
stated that the legislative history of the -Clean Air Act indicates
that vehicles need  only meet standards on the  average.   In iaddi-
tion, IHC felt that  the imposition of  a   10 percent  AQL would have
an adverse economic impact on the  light-duty truck industry,  so it
should be relaxed as  it was in  the light-duty vehicle SEA regula-
tions.   IHC provided  an  analysis  in which  the design targets
necessary to meet a 10 percent AQL for  SEA were estimated to be .26
g/mile for HC and 3.2 g/mile for CO.

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     IHC recommended that EPA retain the present 40 percent AQL to
avoid  imposing  a much more  stringent  emission  standard than Con-
gress intended.

     Cummins Engine Company,  Inc.  (Cummins)

     Cummins believes that the potential  impact  of  * 10  percent AQL
must be  carefully studied.   Cummins  stated that  due  to moderate
test-to-test variability  and vehicle  design  tolerances, manufac-
turers would  need to  design their  products  to meet  an emission
level which is significantly  lower than the  legislated requirement.

     Volkswagen (VW)

     VW  stated  that  to comply with a  10 percent  AQL  for the pro-
posed  emission  standards  it  would be  necessary to use  the closed
loop controlled three-way catalyst concept.  VW  estimates that a 10
percent AQL would require the average emission level to  be about 20
to  30  percent  below  the  engineering  goals currently used  by VW.
This reduction  is solely because  of  the measuring uncertainties.
VW  did not provide  an analysis  to support  its  estimate  of the
percent reduction necessary to meet a 10  percent AQL.

     VW  recommended  that  "until  government  together with industry
can minimize these  uncertainties,  the AQL  should remain at 40
percent."

     Toyota Motor Co. Ltd. (Toyota)

     Toyota does  not  agree with EPA1s proposing  a 10  percent AQL
instead of a 40 percent AQL because this  manufacturer believes that
a 10 percent AQL is not consistent with the  intent  of the Clean Air
Act.

     b.  Other Commenters

     Motor Vehicle Manufacturers Association (MVMA)

     MVMA's main  comment  was that the 10  percent  AQL  is not con-
sistent  with  an averaging concept for  determining compliance with
standards.  Its arguments were based on  the legislative history of
the Clean Air  Act,  statements of past EPA  Administrators, the
averaging  concept  embodied  in  certification  regulations,   ambient
air quality  studies  based on averages,  the statutory  language in
Sections 202(a) and 202(b),  and  the inclusion  of averaging concepts
in the Regulatory Analysis for the NPRM.

     U.S. Department  of Commerce  (DOC)

     The DOC commented that there  is no rationale  in the NPRM  for a
10  percent  AQL.   DOC stated if  a 10 percent  AQL is  established
engines  and emission control  systems must  be designed  to emit

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 levels  of pollutants  considerably below  the  levels  permitted  by
 certification.   DOC believes that  a  10 percent AQL  will  increase
 component  costs  significantly,  may require more  sophisticated  and
 expensive emission  control hardware and would  involve a fuel
 economy  penalty.   DOC did not supply  an  analysis  supporting  these
 statements.   DOC recommended the  retention  of the 40  percent  AQL
 for LDT.

     U.S. Council on Wage and Price Stability (COWPS)

     COWPS stated  that the  compliance  cost estimates  contained  in
 the  EPA Regulatory  Analysis make  no  allowance for  any  increased
manufacturing costs associated with the 10 percent AQL.

     COWPS also suggested that the 10 percent  AQL may go beyond  the
 statutory mandate  because  it  will  require  either  a  very  low
variance in the  test  results for  production vehicles  or an average
 level  of emissions  which  is low relative to  the standard.    For
 these  reasons  COWPS  recommended  a cost-benefit  analysis  be per-
 formed before a 10 percent AQL is established.

     3.  Analysis of the Comments

     Since many  of the manufacturers  and  organizations responding
made similar comments  on the AQL  issue, each of the major  comments
will be  discussed  under  a  separate  heading   in  this  section  for
purposes of clarity.   For further  information relating to the  10
percent AQL issue,  reference is  also  made to  the  economic impact
and the cost-effectiveness studies  in  Chapter  V and Chapter VII  of
the Regulatory Analysis and  to the  discussion  of  the  technological
feasibility of the  emission  standards in  the  Summary  and  Analysis
o f Comment s.

     a.  The  10 Percent  AQL  is Consistent  with Congressional
         Intent

     When reviewing the comments  to the NPKM on SEA for light-duty
vehicles in 1976, the EPA Office of General Counsel (OGC) reached a
finding  that   "...Congress   intended  that, eventually,  every  car
coming off  the  assembly  line should  meet the emission standards
established under Section 202."  A  copy of the memorandum  contain-
ing this finding (General Counsel  Opinion  No.  76-4) is available  in
the Public Docket   for  this  Rulemaking.   OGC  acknowledged that  a
phasing  in  of  this  requirement  was   appropriate  to  avoid imple-
menting SEA in an  unreasonably burdensome manner,  so  long a!s  the
ultimate goal  of full compliance is not abandoned.   As  explained [in
the LDV  SEA  preamble  (41 FR 31474,  July  28,   1976),  auto  manufac-
turers  argued that  implementation of a  10  percent  AQL would have a
disastrous economic  impact on the industry,  since  it would result
in a loss of  certification for a majority  of engine families.  A  40
percent AQL was therefore established  to implement  SEA  in  a manner
not unreasonably  burdensome  to  the  affected  manufacturers.  This
initial  approach was designed to  "provide manufacturers  the time

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and  flexibility  to  bring  all  their vehicles  into  conformance with
the standards on a reasonable  schedule" (41 FR 31475).

     Section 206(b) of the Clean  Air  Act  provides  for  SEA  testing
of  light-duty trucks.  EPA maintains  the  position  that  there is  a
specific legal  basis  for requiring every  LDT coming  off the
assembly line to meet emission standards.  The full text of  the EPA
General  Counsel  memorandum,  mentioned  above,  explains  that the
language of the Clean Air Act and  the relevant legislative  history
support an  "every  car"  approach to compliance  with emission
standards.

     The  ultimate  goal  of every vehicle  and engine complying
with  emission standards is  also supported by  the U.S. General
Accounting  Office(GAO).   The  GAO did not  take  issue with  EPA's
legal  interpretation of the Clean  Air  Act  on this  matter and
recommended that the current  LDV SEA program be revised to  "...re-
quire  a  Federal  emission  standard compliance  rate  more indicative
of the current rate for car configurations tested, which is  well  in
excess of the 60  percent  passing  rate required."   (GAO Report CED
78-180, p. 28).

     b.   The Relationship Between the Standards and a 10  Percent
          AQL

     Section 202(a)(3)(A)(ii) of  the  CAA states, in pertinent
part,  "...  regulations  .  .  . applicable to emissions from vehi-
cles or  engines manufactured  during and after model year 1983,  in
the  case of HC  and CO,  shall  contain  standards  which require  a
reduction of  at  least 90  percent  .   . .  from the  average  of the
actually  measured  emissions...during  the baseline  model   year."
Pursuant to this requirement,  EPA conducted  a  test  program  on 1969
model year light-duty trucks (the  last model year before imposition
of  HC/CO standards for  light-duty  trucks).  Using  the   sales-
weighted average emission levels obtained  during this  program, the
standards were then set by multiplying these levels  by  10 percent,
i.e., a 90 percent reduction.   These numbers, once identified, then
became the required standards.  The 10 percent AQL does not  change
the values  of the  standards;   it  merely  reflects EPA's view that
every  production  vehicle  must  comply  with  the established  stan-
dards.   This is  consistent  with  EPA's  finding,  as discussed   in
Section 3(a),  that every  production vehicle must  comply with
standards  established under Section 202 of the  Clean Air Act.
Also,  as explained  in the legislative history  of Section 202(a)(3)
(A)(ii), Congress  intended that  production  line  testing of  heavy-
duty vehicles ensure  that "each  production vehicle  will comply  in
actual use."  H.R.  Rep.  No.  95-294, 95th Cong.,  1st Sess. 276
(1977).  See  also  H.R.  Rep. No.  95-564,  95th  Cong., 1st Sess. 171
(1977).  This language conclusively answers manufacturers arguments
that  by use  of  the  term "average"  in  Section  202(a)(3) (A) (ii),
Congress meant to reject the "every vehicle" concept.

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     EPA  has performed an  analysis  which indicates that  a 10
percent AQL can cause  a manufacturer  to  design  to  lower target
emission  levels than those required by a 40 percent AQL.  However,
the magnitude  of  the difference between the target levels depends
on  several  factors, some  of which are  within the manufacturer's
control.  One  of  the most  important of these  factors is the vari-
ability of  identical  production engines (the  "width" of emissions
distribution) at each design level.  By increasing quality control
and minimizing  other  variations in the manufacturing and assembly
process,  the manufacturer  may reduce  variability and  raise  the
target  emission levels  which it needs  to meet.   In practice,  the
Agency believes that each manufacturer  will  trade off to one degree
or  another  lower  design targets versus stepped-up quality control
to  obtain the  most  cost-effective  approach  towards the 10 percent
AQL goal.

     c.  The Consistency of the 10 Percent AQL with the 40 Percent
         AQL  in Effect for the Current Light-Duty SEA  Program

     The  40  percent AQL was established  for  the  current  LDV  SEA
program to  implement  the  program in a manner  not unreasonably
burdensome to the affected  manufacturers.   At  the time the current
LDV SEA was  proposed,  several  auto manufacturers stated that they
built the average production vehicle to meet the standards.  It is
important  to note  that  the  situation at  the  time the 10 percent AQL
was proposed for the current LDV SEA program is different from the
situation  today.  As discussed  in  the  Preamble to the current LDV
SEA regulations:

     "The approach  taken here,  then, of not setting the AQL at 10%
will provide manufacturers  the time and  flexibility  to  bring  all
their vehicles into conformance with the standards on a reasonable
schedule.    Such  a  schedule can be  compatible  with their parallel
efforts to  improve  fuel economy  and  which  does not  expose  them
unduly to the risk  of loss  of certification while they are learning
to  bring  their  production  vehicles  into compliance with the law."
(41 FR 31475, July  28,  1976).

     The circumstances under which  the proposed LDT SEA program is
being  promulgated   are  significantly  different  than  those  under
which the current  LDV  SEA  program was  promulgated.   When the LDV
SEA  program  was promulgated the  emission  standards  were already
established   for then-current  and future model years  and manufac-
turers were  building vehicles  to meet the  standards  on  the aver-
age.   The short notice  that manufacturers  were  given  before  the
proposed implementation of  a 10 percent  AQL .for the LDV SEA program
would  not have provided sufficient  time  to  make the necessary
design  and  production changes, thus causing a severe  economic
impact  on them.   The  proposed LDT  SEA program  will not  be in
effect  until  2 1/2 years  in the  future; EPA  has  determined that
this is this  is sufficient  leadtime to comply  in a cost-effective
manner with all of  the  1983  regulatory requirements, which include
the 10 percent AQL.  (See Section E of  the  Summary and Analysis of
                                I GO

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Comments for a discussion of "leadtime.")   The LOT industry was put
on notice  in 1976 that  EPA intended  all  motor vehicles to comply
with the standards when  the Agency made the  above  statement in the
Preamble to the current LDV SEA regulations.   When the  proposed LDT
regulations  go  into  effect in  1983,  the industry  will  have had
seven years to develop the quality control procedures and institute
the design changes necessary to meet  a 10  percent  AQL.

     EPA's  approach  in the current  LDV SEA  program,  the  HDE SEA
program and the proposed LDT SEA program  is  a consistent one:  The
Agency has  endeavored to implement  an SEA program consistent with
its  legal  interpretation  that  every vehicle  or  engine must meet
standards and in  a practical  manner  that  does not place an unfair
or unreasonable  economic or  technological burden on  the affected
industry.   In  the LDT  case,  the Agency has determined  that the
final standards,  in  combination with a 10  percent AQL, are  tech-
nologically  attainable  and  can be implemented in  a  cost-effective
manner (see Chapter VII of the Regulatory  Analysis).

     d.  Relationship of a 10 Percent AQL Program to Certification
         Requirements

     Several commenters  indicated  that they  felt  the  present
certification  program  embodied  an  averaging concept  which  con-
flicted with  the  concept  of  a  10 percent AQL.   They  argued that
consistency  required  use of a  40 percent  AQL so  that  essentially
the  average  engine  emission  level  would  meet thfe  standards.

     The  staff does not  agree with this  contention.   Section
206  of the Clean Air  Act authorizes a certification  program
(206(a)) and an  assembly line  testing program (206(b)).  If  a new
motor vehicle or engine design demonstrates compliance  with Section
202  standards  throughout  its  useful  life,  a certificate  of con-
formity will be  issued under 206(a)  regulations.  The certificate
is issued  with  respect  to  Section  202 regulations, i.e., regula-
tions establishing emission standards.   Since the function of the
assembly  line  testing program  is "to determine  whether new  motor
vehicles  or engines  being manufactured  do   in  fact conform with
regulations with respect to which the certificate of  conformity was
issued,"  the  program  will determine compliance  with  emission
standards.

     The EPA certification  and  SEA programs  attempt to accomplish
different but related  objectives.  Because of the  differences, the
programs need  not necessarily  employ the same  approaches towards
compliance.   Through  certification,   a  manufacturer  demonstrates
that  it has the capability  to design  a vehicle or  engine that will
comply with  emission  standards  promulgated  under  §202(a) through-
out its useful  life  under  conditions  simulating  actual use.   Once
these  prototype  vehicles  or  engines  demonstrate  compliance, EPA
issues the manufacturer a certificate of conformity  allowing  it to
actually manufacture vehicles or engines  similar to  the prototypes
for distribution into commerce.   Then  SEA  requires  the  manufacturer

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to  demonstrate  that  newly  manufactured vehicles  or  engines will
also  comply with  standards  throughout  their useful  lives.  As
discussed  in  section a, EPA  has  determined that  every production
vehicle or engine must be in compliance.

     e.  Cost Impact of the  10 Percent  AQL on Light-Duty   Truck
         Manufacturers

     There is a cost  component  attributable to the 10 percent AQL,
as  there is to all other compliance  options in the  regulatory
package.   A light-duty  truck manufacturer will  actually  incur a
"10 percent AQL"  cost in those cases  where it experiences diffi-
culty  in attaining the target emission  levels, i.e., when the
manufacturer must spend more  money  in  going to the 10  percent AQL
target level from some other  (higher)  level, or where it decides to
step up  its in-house  quality  control  programs  in response  to a 10
percent AQL.

     A cost-effectiveness analysis has  been performed   in conjunc-
tion with  the evaluation of  this  regulation.   One option examined
was the cost of  the proposed  SEA program at  <± 40  percent AQL versus
its cost at a 10  percent  AQL.  The analysis indicated that the 10
percent AQL SEA program is the more expensive  option, but that the
cost of  moving  to  the  10  percent AQL  is small  relative  to  a 40
percent AQL.

     f.  Air Quality Impact of a 10 Percent  AQL

     EPA has performed an  analysis of  the  reduction in emissions to
be obtained in going  from  a  40 percent AQL to a  10 percent AQL in
the SEA  program.   This analysis appears  in  Chapter  VII  of the
Regulatory Analysis.  The  findings  of  this analysis  indicate that
by implementing  a 10  percent  AQL  LDT  HC emissions will be reduced
an average  of  .006  tons per  vehicle  over the  vehicle's lifetime,
LDT CO  emissions will be reduced 0.2  tons,  and LDT  NOx emissions
will be reduced  0.04 tons.

     As  shown  on Table  VII-A  in the  Regulatory Analysis,   these
reductions  represent  a  positive reduction  in  HC, CO and  NOx for
LDTs which EPA analyses have  shown  can be achieved  in  a  cost-
effective manner.    On the  basis of  dollars spent per ton of  emis-
sions  removed,  the 10  percent  AQL compares  favorably  with  other
emission control  strategies.
                                                             I
     g. -The Effect  of the  10  Percent AQL  on Fuel  Economy     /   I
                                                             ;
     In order  to  go  from meeting the proposed 1983 LDT standards at
a 40 percent AQL to meeting these standards at a  10 percent AQL it
will be necessary to  :  1) upgrade the  air  injection system of one
LDT, 2) add EGR to  a diesel  LDT configuration, 3) recalibrate the
EGR on  some gasoline LDTs,  4)  change  the  engine calibration for
some LDTs  and  5)  increase the  average catalyst  loading slightly.
(See the discussion of  the  10 Percent  AQL Compliance Costs in the

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will involve  a small fuel  economy  penalty.   When estimating the
fuel  economy  impact of  this  package,  EPA  determined  that if
the manufacturers  ignored  fuel  economy considerations  in  design and
introduced  no  new  technologies,  the overall  fleet  fuel economy
potential will be reduced  less  than 4 percent.   The 10  percent AQL
would account  for  a negligible part  of the fuel  economy penalty
under this scenario.   EPA  believes that  LDT manufacturers can  avoid
a  fuel  economy penalty entirely  by using electronic engine con-
trols.    (See  the  discussion  on Fuel Economy  in the Summary and
Analysis  of Comments.)   Electronic  engine  controls  are already
being used  in  1980 passenger  cars,  and  EPA believes that in 1985
most LDT  manufacturers  will use them to meet  the  tighter NOx and
fuel economy standards.

     4.   Staff Recommendations

     It  is  recommended  that  a 10 percent  AQL be  promulgated
in  the  Final  Rule.  An  SEA  program  with  a 10  percent AQL is
consistent  with  EPA's  legal   interpretation  of the  Clean Air
Act,  does  not place  unreasonable cost  burdens on  light-duty
truck manufacturers, results in a positive reduction  in  emissions,
has no  significant  impact  on  fuel  economy,  and is technologically
feasible, given the emission standards to be promulgated.

Other Selective Enforcement  Auditing Issues

     1.   Definition of "Configuration" (§86.1002(b)).

     EPA  proposed that  a light-duty truck (LDT) configuration
be "...described on  the basis  of... other  parameters which may be
designated by  the Administrator."   GM contested this  definition as
being unreasonably  broad  and  vague and wanted  protection against
arbitrary selection of parameters by EPA.

     This provision  about "other  parameters"  is similar  to a
provision contained  in  the present  light-duty vehicle  (LDV) SEA
definition of  "configuration".   A LDV configuration has  never been
defined  beyond  the specific parameters  contained  in that defini-
tion.   Present  LDT configurations  can  be described  using the
specific parameters in the LDT  definition.  However, EPA needs some
flexibility   in  specifying  configurations,  because  new  emission
control   technologies developed  in  response  to 1983 and  later LDT
standards may  result  in emission  control  parameters  not presently
identified.    EPA does  not  intend   to use this  flexibility  in an
arbitrary manner but  has  retained  the  proposed  definition in the
final rule.

     2.    Low  volume LDT  families  are  not exempt from SEA test
          orders (§86.1003).~~

     This exemption  was  not  included in the  proposal.   MVMA
recommended that  if the "projected  sales  volume for  a  given
                              101

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code  is  less than  2,000 trucks  for  the current model year the
manufacturer should be permitted, upon receiving a  test  order,  to
petition the Administrator  for an  exemption from Selective Enforce-
ment Auditing of that  engine code."  Section 206(b)  of the CAA does
not exclude any particular  class or category of production vehicles
or production engines  from  its provisions.  Therefore, from a  legal
standpoint, all production LDTs  are potentially subject  to testing
to determine compliance with applicable emission standards. From a
practical standpoint,  to  the extent that test orders  for  low volume
configurations are  issued, EPA  believes  that  its newly  developed
sequential sampling plans  allow these  configurations  to  be tested
as expeditiously as  possible because, with these plans, as few as 7
LDTs are  required to  pass  an audit,  and  the  LDTs to be  tested may
even be  selected over  several days.   Therefore,  the  impact  on
customer delivery  schedules should  be  minimized.   Because the
sequential  plans  allow  the  flexibility  to  deal  with  low-volume
configurations,  no  change  has  been made  in  the  final rule.

     3.   Statement  about "...instructions  in the test order1'
          is not  redundant  and unnecessary (§86.1003(b)).

     GM stated that  this  phrase,  in the last  sentence of  paragraph
(b), should be eliminated because  the CAA mandates  compliance  with
test orders  issued  under  regulations.   EPA prefers  not  to delete
the phrase  because  it alerts  the manufacturer of its obligations
directly in the regulations under  Subpart K.

     4.   Vehicle selection procedures in the test  order  (§86.1003-
          83(c)(D).

     The  proposal  stated  that  "the  test order will specify...
the procedure by which LDTs of  the specified  configuration must  be
selected."  GM stated  that this  statement was vague  and  ambiguous.
Both GM  and  MVMA said that this  allowed  too  much  flexibility and
could  impede the expeditiousness of  the audit and that by not
including these procedures in the  regulations  EPA was denying the
LOT manufacturers the  right to comment on them.

     EPA  has  made no changes  in  its  proposed statement for the
final  rule.   Commenters stated  that  if  procedures  can be  stan-
dardized, they should  be  placed  in the regulation.   However,  it  is
not possible  to  standardize  the selection process because of the
different production procedures encountered  at   the  assembly
plants.   Neither  GM nor  MVMA offered  any useful suggestions  as  to
how  to standardize selection  techniques.    In addition, EPA's
experience with  selection, during the current SEA  program,  indi-
cates  that  it  is necessary to  have  flexibility in  the  selection
process  to  account  for  the  unique situations encountered during
vehicle selection at different assembly plants.  EPA intends to use
the flexibility  to  expedite  vehicle  selection and  therefore  does
not believe that this will  impede  the  progress of audits.   It
should be emphasized that paragraph  §86.1007-83(a) allows for
manufacturer  input  into  the determination of the  selection  pro-
cedure.

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     5.   Other  standardized  test order instructions (§86.1003-83
                      ~                ~
     EPA  proposed  that  "In  addition,  the  test order may  include
other directions or information essential to the administration  of
the required testing."  GM stated  that  this statement was vague and
ambiguous:   "Any  procedures which  can be  standardized  should  be
placed in the regulations and information deemed to be "essential"
should also  be  included so that  the manufacturers  are  not  effec-
tively  precluded  from  commenting on such information or pro-
cedures ."

     EPA  has determined  that  some of the  specific  instructions
presently incorporated  in  LDV  SEA test  orders  are applicable
to LOT SEA  testing and  has included them in the final  rule  as new
paragraph  §86. 1003-83(c) (2) .   As the   need  for new  instructions
which can be standardized becomes apparent  in the future we  intend
to amend  the regulations to  incorporate them.   However, the pro-
vision to  include  "other directions or  information"  essential  to
administer SEA testing has been retained to allow some flexibility
in SEA operating  procedures.    This  flexibility  can  be  in the
interest of  the  manufacturers and EPA,  as  it will  allow audits  to
be conducted  in  the most expeditious manner  practical, given
circumstances unique to  a particular manufacturer.

     The  latitude  built into the test  order and  sample selection
sections  of  the  SEA regulations is  intended  to  accomodate pro-
cedural  variations,  especially in the area of  LDT selection.
Specific instructions  may  be made  to minimize  the  impact  on
each  manufacturer's normal  production activities  while still
assuring the generation of accurate,  representative test results.

     6.   Selection at non-preferred plants (§86.1003(d)K

     EPA proposed  that, even though  a manufacturer  has submitted a
list  of  assembly plants preferred for  LDT  selection,  "the  Admini-
strator may order testing at  other than  a preferred plant."   GM and
MVMA  believed that manufacturers  should  be  able  to designate from
which plant  a specific  configuration will be selected.   GM  stated
that  it  was  necessary  for  the  manufacturers  to  designate those
plants in order  to ensure that vehicle selection does  not  disrupt
normal  production practices  at some  plants and  to  allow the
manufacturers  to  have  an  input  into the  selection process.

     The  sequential sampling plans  contained  in  this  regulation
were designed to allow  flexibility in sample selection to prevent,
to the greatest  extent possible, disrupting a manufacturer's  normal
production and  delivery schedules.   EPA intends to select the
sample of LDTs at preferred locations,  but requires the flexibility
of selecting at non-preferred  plants  when  that  would  allow the
audit to  be performed more expeditiously or permit  the auditing,
based upon available evidence,  of specific  cases of noncompliance.
To retain this  flexibility, EPA made no  change to  the final rule.

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     7.   Clarification of the  projected annual  sales used  in
          determining the annual  limit on test orders.  (§§86.1003
          (f)(l)(i)  and 86.1003(f )(l)
     EPA  proposed that  the annual  limit of SEA  test orders be
calculated using the projected  "sales for that  year."   Although no
comments  were  received  on  this  issue these paragraphs have  been
revised to  specify  that  the annual limit is calculated using  the
projected "sales bound for the  United States market for that  year"
in order to clarify  the  intent  of these paragraphs and  to make them
consistent with  the previously promulgated heavy-duty engine
regulations (44 FR 9488,  February 13,  1979).

     8.   Test orders  that will count against  the annual  limit
          (§86.1003-83(f)(2), (3)).

     EPA  proposed that  test  orders  will not count  against the
annual limit under the following circumstances:

     (1)  The configuration being  tested fails  according to  the
          sampling plan decision criteria;

     (2)  Testing  is  not  completed;

     (3)  The test order  is issued on the  basis of  any  evidence
          indicating  noncompliance with the AQL; and

     (4)  Follow-up  audit testing is  conducted on  a configuration
          which previously  had its certificate  of conformity
          suspended  or revoked.

GM, Chrysler  and  MVMA stated  that  failed  test orders which  pass
a follow-up audit and test  orders  issued on  the  basis of  evidence
of noncompliance should  count.   They said if these  test orders did
not count,  there  would  not  be an  upper limit  and manufacturers
could not plan the extent to which  facilities must  be  allocated to
meet this requirement.

     Because  of  its responsibility  to investigate  those LDT
configurations for which  it  has evidence of noncompliance,  EPA will
not establish  an  absolute limit on  the  number of  test orders it
will  issue.  However,   EPA is sensitive  to the  manufacturers'
concerns that they may be subjected to an indefinite number of test
orders.  Therefore,  the  proposal  has been amended to provide  that,
when based on evidence of noncompliance, a test order issued within
the annual  limit  will count toward the annual limit,  if  the' con-
figuration passes  the  audit.   If the  limit  has  been reached,
additional test orders  can be issued only on the  basis of  evidence
of noncompliance.  In addition, the provision requiring a statement
of the reason for  issuance of a test order beyond the  annual  limit
will be retained.

     Follow-up audits do not count  toward the annual limit because
                                 106

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they fall under the  "umbrella" of  the  original test order, which
resulted  in a fail decision;  see paragraph  §§86.1012-83(j)(2)
and  (k)(2).   The  only exception to  this  provision  is  when a
configuration,  having had  its certificate  of conformity suspended
or revoked by EPA,  is  then "replaced"  by another configuration that
was previously certified.

     9.   Selection of test vehicles by  the Administrator (§86.1004
          (a)).

     EPA  proposed  that when SEA  testing  will  be  performed by
the Administrator, he will  select LDTs "...in  a  manner desig-
nated  by  him..."  GM  suggests that this  provision  be   revised so
that  LDTs  are selected  in  accordance with §86.1007-83.  EPA
intends to  select  LDTs for its own testing  in a manner  consistent
with  the  standardized selection  procedures  established  in con-
sultation with that manufacturer'.    The  final rule  therefore
includes  the statement that the Administrator  will  select  his
test LDTs "...in  a manner consistent with  the  requirements of
§86.1007-83..."

     10.  Discrepancies between EPA  test results and manufacturer
          test results.  (§86.1004(b),  (c)).

     EPA  proposed  that its  test results comprise the official
data for  a test vehicle  when there  is a disagreement with the
manufacturer's results.   GM  disagrees  with  the assumption that
the manufacturer's  test  facility is  deficient and  that it bears
the burden of proving that  its own  data is  correct.   However,
the regulations provide two  mechanisms  for  resolving  differences
between data:  (1)  paragraph § 86.1004-83(c)(2) allows a manu-
facturer  to demonstrate  that EPA's  data  were erroneous and  its
own data was  correct;  and  (2)  if EPA invokes  a  suspension of
the certificate of conformity based  on the  Administrator's test
data,  the manufacturer  can  request  a hearing  under  paragraph
§86.1012-83 (1) to determine whether the  tests were conducted
properly.  Therefore,  EPA is not changing this  provision.
                    I
     11.  Retaining  names  of personnel (§86.1005-83(a)(2)(iii),
          TTvTT:	

     EPA  proposed  that the manufacturers be required to  retain the
names of  all  personnel involved  in the conduct of the  test  and in
the supervising and performance  of  a repair.   GM objected to these
requirements,  stating  that   the  information  "is  unnecessary  and
irrelevant for EPA's  needs and goes beyond that required by current
LDV and LDT regulations."

     EPA believes that the names of manufacturer personnel involved
in  SEA audits should be  available  if an investigation of the
conduct of an audit is necessary.   However, EPA does agree with GM
that it  is  unnecessary  to include this information in  the audit

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suggested by  GM,  but paragraph §86.1005-83(a)(2)(ii)  in the final
rule requires the manufacturer to  retain  the names of all personnel
involved in the audit for future reference.

     12.  Requirement for submitting manufacturer's test results
          (§86.1005(c)).

     Several manufacturers were critical of the proposed provision
requiring them to  submit  their  own  production LDT test  data.   GM,
Ford,  Chrysler,  Toyota and  MVMA  considered  this  requirement  un-
reasonable and an unjustifiable burden.  GM stated that  these data
do not necessarily reflect overall production  emissions performance
throughout the model year.  GM  and Toyota objected to EPA's use of
this data for enforcement  purposes and  along with Chrysler believed
that  this  is a  deterrent for  manufacturers  to  continue in-house
auditing.   Chrysler believes that  this requirement  is  not  in
conformance with  the Clean Air Act.  Chrysler  stated that "Congress
intended that the  Administrator be  only  entitled  to  access  to the
data  he needs  to  determine  compliance  on a  specific basis".
(Chrysler's emphasis) Ford and MVMA  also  believed that data submit-
ted to EPA  should  be limited.   MVMA suggested that only data from
complete emission  tests of production vehicles  need  be  submitted.
Ford proposed that the manufacturers only be required to report the
results of regularly scheduled tests.

     Subpart K does not impose  any requirement that a manufacturer
conduct an internal  quality  audit program, but  if it  does conduct
this type of  program,  Section 208(a)  authorizes the Administrator
to require the submission of this data  because  the  data can  help
determine compliance  of  LDTs with  applicable emission  standards.
This requirement  has  been proven  workable in the  LDV  SEA program
and does not appear to be  unreasonably  burdensome to manufacturers.
EPA believes that the reporting  requirements  it  proposed  for
the LDT  manufacturers are reasonable because  these  requirements
are similar  in  scope  to  those currently  being  met by  LDV manu-
facturers.   However, EPA has made  two changes  in  response  to
comments received:   (1)  The manufacturer  is  required to describe
the emission test used to  obtain the data submitted;  see §86.1005-
83(c)(l).   This  change  will help EPA  determine  the  degree  of
correlation between a  "short   test"  result,  if  the  manufacturer
uses this kind of test,  and  full FTP  data.   (2)  The manufacturer
need only submit data  on  ADP storage  devices  if these devices are
compatible with  EPA equipment.  EPA will furnish the necessary ADP
storage devices upon a manufacturer  request.

     13.   Entry and access (§86.1006).

     Ford contends  that  the provision allowing EPA inspectors
to  "inspect and  monitor  any aspect  of engine  or  vehicle  test
procedures or  activities1' is  beyond   EPA's  authority  in the  CAA
because it would allow EPA to  have  access to those areas of manu-
facturing facilities which have no  connection at  all  to a legiti-
mate EPA  interest.   Ford wants  EPA  to  limit  its  inspections  to
                                  1C*

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those  items  specifically  listed  in  Section  86.1006-83(b)(2) .

     Section  206(c) of the  CAA allows  EPA "... (1)  to enter,  at
reasonable  times,  any plant or other  establishment of  such  manu-
facturer, for the purpose of conducting tests of vehicles ...  or
(2)  to inspect,  at  reasonable  times,  records,  files, papers,
processes,  controls,  and  facilities used  by  such  manufacturer  in
conducting tests under regulations of the  Administrator."  Ford did
not explain how EPA was  exceeding its  authority in Section  206(c)
or any other  section  of  the CAA.   EPA must be able to monitor and
inspect  any  aspect  of vehicle  test  procedures  and activities
necessary  to  assure  that  these  vehicles are being  prepared  and
tested  according  to  applicable  regulations  and  the prescribed
Federal  Test Procedure.    In  addition,  EPA  at  this  time cannot
develop  a specific comprehensive  list of all test procedures  or
activities which could require  inspection or monitoring during the
course of an audit.   If  Ford belieVes that  EPA is conducting  an
inspection  in excess  of  its authority, it may  not  consent  to the
inspection.   The Supreme Court  decision in Marshall vs. Barlow's,
Inc.. has limited  inspections  without  a  search warrant  to  those
which have  the manufacturer's  consent.    If  voluntary  consent  is
refused,  EPA  will   not  attempt to  enter  any of a manufacturer's
facilities,  including emission testing facilities, without  first
obtaining a  search  warrant.   GM  suggests  that  only  "emission
related"  parts  be  investigated   in paragraph  §86.1006(b)(4), but
gave no  reason for this  comment.   §86.1006(a)  states  that  only
matters  related to Subpart K  will  be  investigated.  EPA has not
revised §86.1006 in response to these comments.

     14.  Entry and access in foreign  jurisdictions (§86.1006(g)).

     EPA  proposed  that foreign testing and  manufacturing facili-
ties   must  be  located so  as  to  permit EPA entry  and  access.   VW
requested  that  this  requirement  be deleted  because manufacturers
have no control over a country's policy.

     EPA has made no change in its proposed statement for the final
rule.   To allow a manufacturer  to produce vehicles  in  a country
which did not permit EPA to conduct  inspections would inhibit EPA's
ability  to enforce  air  pollution  regulations   at  that  location.
Further,  it would  give that manufacturer  an  unfair advantage over
other manufacturers which are  subject  to  EPA  inspections.   When a
manufacturer decides to locate  an assembly  plant in  a foreign
country,  one  of the risks  it  is .voluntarily  accepting is that the
country will  continue to  allow EPA inspectors to conduct assembly
plant inspections  within  that  country.  EPA must  be able to conduct
inspections  at  these  foreign assembly plants   to  accomplish  the
tasks mandated by Congress.

     15.  Authorization  for personnel appearances  and  entry
          without  24 hours  notice.  (§86.10Q6(h)(4)).
                                  /tf

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     GM  recommended  that proposed  paragraph  §86 . 1006-83(h) ( 4)
be  amended to  require approval  of  the Assistant Administrator
for  Enforcement before  manufacturer  personnel  could  be questioned
by  EPA  investigators.   GM and VW also recommended adding  a  new
paragraph §86. 1006-83(h) (5) which  would require the Assistant
Administrator to  sign test orders in  which  manufacturers  are  not
given  24 hour notice before entry.  EPA believes it is unnecessary
to require the  Assistant  Administrator to authorize either appear-
ances  of personnel or  entry  without  24 hours notice  because these
authorizations can be  performed by other responsible Agency offi-
cials.   If a  manufacturer refuses  to  consent to personnel appear-
ances  or  entry  without  24 hours notice,  EPA  is required  to seek a
search warrant before attempting to conduct  these activities.
Therefore, no changes  relating  to these issues have been  made  in
the final rule.

     16.  Order  of test results  (§86.1007(e)) .

     EPA  proposed  that  the test  order  will  specify the  order  in
which  test  results will  be  used   in  applying  the sampling  plan.
This  paragraph was  also proposed in the rulemaking concerning
gaseous  emission  regulations  for  heavy-duty  engines  (HDEs)  (44 FR
9488,  February  13,  1979).   Based  upon a comment  received  during
that rulemaking,  EPA changed the   final version  of that  paragraph
(45 FR 4173,  January 21, 1980).   The  revised  paragraph  specifies
that  the order  of  sample selection determines  the  order of  the
decision  sequence.   Although no  specific  comments  were  received
relating to this paragraph during  the 1983  LDT rulemaking,  EPA  has
revised  this paragraph, to be consistent with the HDE regulations,
for purposes  of uniformity and clarification.  This will  provide a
consistent  basis  for applying test  results to  the sequential
decision criteria.

     17.  Retention  and shipment  of test vehicles (§86.1007(f)) .

     EPA proposed  that  all  untested  LDTs  in the  test sample
be kept  on hand until a pass or  fail decision is  reached.   GM
indicated this might  involve  the selection of the maximum number of
test vehicles before testing began and  their  retention  until  the
audit was completed.  Under the sequential  sampling plan,  vehicles
may be  selected as  required  to  assure expeditious testing.   The
maximum number of  vehicles associated with a  sampling plan need  not
be selected prior  to initiating  testing.  Further,  any LDT  which
has passed the  required  emission  test  during the SEA audit may be
shipped.  However, once a manufacturer ships  any LDT from the test
sample,  as defined in  §86.1002-83, it relinquishes its prerogative
to conduct retests during that audit.

     18.  Allowance  for  a "dealer  preparation" procedure (§86.1008
     GM, Ford, MVMA, Chrysler and AMC believe EPA should allow the

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manufacturers to conduct a predelivery inspection on SEA vehicles.
GM,  Chrysler and  Ford believe  this  inspection is necessary  to
assure that  the  results  of SEA  testing are  representative of  the
emission  levels  of vehicles  on  the  road.   GM  states  that disal-
lowing  the dealer preparation  increases the  stringency of the
emission  standards  because EPA  would  require the manufacturers  to
build cars  which meet  the  deteriorated  emission standards off  the
assembly  line.   GM also  believes that  this action is inconsistent
with  §85.2108  of  the  recent NPRM  on  207(b)  Warranty Regulations.
AMC  stated  that  disallowing the  predelivery  inspection would
force them to institute extra   inspections on  the  assembly  line.
These extra inspections  would be redundant because  they are  per-
formed by the dealers.

     EPA  believes  that  SEA test  vehicles which have undergone
dealer  preparation procedures  will represent "real  world" condi-
tions only to the  extent  that  these procedures  are  actually  and
correctly  performed by dealers.   §86.1008(b)(l) of  the  proposed
regulations does permit  a  dealer  preparation procedure to  be
performed  if  it  is approved  in  advance by the  EPA Administrator.
§85.2108  of the  proposed Warranty Regulations  requires  dealers  to
furnish  the purchaser  of  a  new  light-duty  motor vehicle  with  a
certificate which  states that the vehicle meets  emission standards
To make  this  certification in good  faith  the dealer would have  to
perform  all emission  related  preparation required  by the  manu-
facturer.   The certificate  in itself does not prove that the dealer
preparation  procedures  are being performed properly  in  the  "real
world".   EPA's experience with  light-duty vehicles (LDVs) indicates
that  in  several  cases, dealer  preparations are  not  performed,  or
are  performed  incorrectly.   For these  reasons,  unless  the  manu-
facturer  can demonstrate  to  the Administrator   that  these dealer
preparation  procedures are carried  out  routinely and correctly  at
the  dealerships, the  Administrator may require  additional infor-
mation,  such as dealer  survey data, which demonstrates that  dealer-
ships  are  performing the dealer  preparation  correctly before
allowing a manufacturer to perform certain dealer preparation
procedures during SEAs.
                     I
     19.  Time allowed  to ship test vehicles (§86.1008(e)).

     EPA  proposed  that  the manufacturers  be  required to  ship
test vehicles to the testing  location within 24 hours of selection,
unless the  Administrator approves a greater shipping time based  on
a  request  from  the manufacturer.   GM  believes that the 24  hour
shipping  time  is  not  applicable to  low volume  configurations  and
requests that a  provision allowing  a greater period of time  to ship
these vehicles be incorporated into  the  regulations.

     EPA  has made  no  change in the  final rule because EPA may
approve  a different time  period  based on a satisfactory manu-
facturer  request.   If  GM can adequately justify more time  for the
situation it mentions a time  extension may  be granted.

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      20.  Option to retest (§86.1008(1)).

      GM  requested  that  EPA revise  this  proposed  paragraph  to  allow
retesting at  any time during  the audit  (as  opposed  to only after  a
fail  decision has  been  reached) and to  delete the  requirement  for
testing  each  LDT the same number  of times.  GM claims  that  these
changes  are  necessary in order to minimize  the  possible logistic,
storage,  and  economic  impacts upon  a  manufacturer's  operations.

      Selective retesting of  test vehicles could bias the test
results  from  a statistical viewpoint, because vehicles not  retested
may produce different results,  in  terms  of  pass  or  fail, than they
did in the  first  test.   Therefore, EPA  will  require  that  each  LDT
be tested the same number of  times.  EPA realizes that there may be
certain  situations  in which retesting  prior to  reaching  an  audit
decision will require  fewer  emission tests to complete  the audit.
Therefore,  EPA has revised  §86.1008(i)  to allow for retesting
before an  audit decision  is  reached,  upon  approval  by EPA  of  a
manufacturer's justified request to retest.

      This provision is  also being  incorporated into the previously
promulgated heavy-duty  engine  regulations for consistency  with  the
LDT approach.  Since EPA considers  this a relaxation  of  the previ-
ously  promulgated  heavy-duty  engine provision,   no  reproposal of
this  paragraph is being made.

      21.   Rounding of final  test results (§86.1009(b)).

     GM  recommended  that the final test  results be rounded to
3  decimal  places,  instead  of the  proposed 2 decimal  places,
to provide for a more accurate computation.   GM did  not provide  any
analysis  to support its recommendation.   Upon review of this issue,
EPA has  revised the method  of calculating  the  final deteriorated
test  results  in SEA  to make  it  compatible  with  the method used
during certification, which  is based on the  number of significant
figures  instead of decimal places.   To  calculate  the  final deteri-
orated test results, the actual emission results  are rounded to  the
same  number of decimal  places  contained  in  the applicable  standard
expressed to  1 additional significant figure.  This number is then
multiplied by the DF and rounded to  the  same  number of significant
figures  contained  in  the standard.  This method will allow  for  a
direct comparison  between the final deteriorated test  results  and
the standard.  This  change  has  also  been  incorporated  into  the
previously promulgated  heavy-duty  engine regulations   for  purposes
of generalizing the rounding  procedure  for all standards.     '
                                                              /   /
      22.  . Calculation of final deteriorated test results (§86.1009
          (c)(l) and (c)(2)).

     GM  believes that  these  proposed paragraphs  should  be revised
to eliminate  the  inconsistency in proposed §86.1009  between  para-
graph (c) and (c)(2).   These  paragraphs  have been amended to remove
the inconsistency  noted by  GM and to clarify the  use of  DFs.  In

-------
GM's  suggested revision of the  proposed paragraphs no mention was
made  of  adjustment  of  DFs  according  to  certification conventions.
Multiplicative DFs which were determined during certification to be
less  than one are set equal to one.   Similarly,  additive DFs which
were  less  than  zero during certification are  set  equal  to zero.
These DF conventions permit comparisons to be made  between certifi-
cation and SEA test results.

      23.  Reporting of  Invalid Tests (§86.1009(d)(5)(iii).

     GM  objects  to the  proposed provision  that requires  the
manufacturers to report the  test  result  of invalid tests  and
the reason for invalidation.  GM states  that this information
is  not required  by  the  Administrator to  determine whether  a
manufacturer  is   acting  in  compliance  with  the regulations.

     EPA  believes  that  this information  is  necessary for  the
Agency to determine  if the decision to  invalidate the test  was in
compliance with the regulations.  The results of all emission tests
performed during  an SEA must be  available  in the event  that  the
Agency subsequently declares valid  an emission  test the manu-
facturer  had  declared  invalid.   For  these  reasons no  change  has
been made to the proposed  provisions.

      24.  Use of test results  following a pass or fail decision for
          a particular  pollutant (§86.1010(c)).

     GM  suggests  that  this  paragraph  be  modified  by adding  a
sentence to indicate  that once the  test  sample  is accepted or
rejected  for  a particular pollutant,  additional test results  for
the  pollutant  will not  be  considered for auditing purposes.

     EPA. has added a clarification to the final rule in essentially
the  form proposed  by  GM,  except  to  change  the  wording  to read,
"Once a pass  or  fail decision has  been made for a particular
pollutant..." to  retain consistency with sequential sampling plan
terminology.

      25.  Batch  Sampling vs.  Sequential  Sampling for Vehicle
          Selection (§86.1007)"

     VW  encouraged  EPA to continue use  of  batch sampling  plans,
because VW  believed an  SEA decision under the  sequential sampling
plan could be made based on results from unrepresentative vehicles.
The manufacturer  stated  that  "the proposed   sampling  technique no
longer ensures that sample  vehicles  are  drawn all across  the
manufacturer's production  output."    VW contended that  since  an
audit could consist  of  one  single sample  drawn at one time,  a
manufacturer could fail an audit on the  basis of  a quality control
problem encountered on  a single  shift.

     EPA is implementing sequential sampling  plans  instead of batch

-------
 type  sampling  plans  because  the  sequential  plans  often  require
 fewer tests  to  reach  an  audit  decision  than  the  batch  plans,  fewer
 vehicles  need  be retained during the audit, and the simpler  deci-
 sion  rules ease  administration.   When conducting an  SEA of high
 volume  configurations  under  the  current  batch sampling plan,
 several  batches of vehicles may be selected  over  one shift. The
 decision  rules  for batch sampling allow for audit failure  after two
 batches.   Therefore,  the risk of failing  an SEA based on  a  single
 shift's  production  also exists  under  a  batch sampling plan.

     If  a manufacturer  believes  it has  failed an audit due to
 quality  control problems,  the regulations provide a mechanism for
 the manufacturer to  prove its contention.   §86.1012(j) allows the
 Administrator to reinstate the suspended  certificate of conformity
 when the  manufacturer:   1)  submits  a written  report which  identi-
 fies the  reason  for noncompliance and describes the proposed  remedy
 and  2)  demonstrates  that  the vehicle  configuration  now  complies
 with  the  standards.  Under  this  provision, if a manufacturer
 believed  it failed an SEA because of a problem  on the assembly line
 during a  single shift, the manufacturer could  have its certificate
 reinstated  after it  submitted a report  describing  this  problem,
 demonstrated  to  the  Administrator  that  steps had been  taken to
 remedy the problem,  and  showed  that  the  vehicles now comply with
 the standards through a reaudit.

     26.   Complexity of the Sampling Plan  (§86.1010(c)).

     Ford concurs  with  the proposed  sequential  sampling plan
 for  SEA  test  purposes;  however, "Ford  is  still dismayed at the
 unnecessary complexity of  the  plan,  as proposed, with its various
 code letters,  annual  sales,  and phases."   Ford  developed  a  single
 sampling  plan  with a  40 percent AQL which  could be  used for all
 engine families  with yearly projected sales above 50.

     Ford did  not explain why the proposed  sampling  plans are
 unnecessarily complex.   The  decision as to which sampling plan to
 use  for   a  particular  configuration is dictated by  the  projected
 annual  sales  of that configuration.   Manufacturers  supply this
 information  to   EPA  in  their  Application for Certification, and
 therefore  the information is readily available to both EPA and the
manufacturer.  EPA does not believe  its  proposed  sampling plans are
 overly complicated.

     The  sampling plan that Ford developed incorporates a  40%,AQL.
 EPA plans to implement a  10%  AQL for  LDT.   Further, Ford's  sampling
 plan requires  the manufacturers to  do more  testing  than would be
necessary  using  the sampling plans  proposed  by EPA.   EPA  believes
 that it  is desirable  to  reduce the  number of  tests a manufacturer
must perform  during  an  SEA  to a minimum.   EPA  has  therefore not
 revised §86.1010(c) in response to this  comment.

     27.  Application of suspension  decisions  to all manufacturing
          plants (§86.1012(6)7!
                                 Hf

-------
      EPA  proposed  that  a suspension decision imposed  on LDTs of a
 failed  configuration produced at one plant could  also be imposed on
 LDTs of  the same  configuration  produced  at  all other  plants.
 Chrysler,  VW and MVMA stated  that  the  proposed regulations did not
 allow for a  partial suspension  or  revocation.   Chrysler  and MVMA
 requested  that  EPA allow the manufacturer « chance to demonstrate
 that a problem was  plant specific before  the certificate was
 suspended  or revoked for that configuration.

      Paragraph   §86.1012-83(e)   states,11. . .the   Administrator  may
 suspend  the certificate...  at all  other  plants" (emphasis added).
 The^use of  the word  "may"  indicates that this  is a discretionary
 decision  on EPA's part and  that the suspension order will not
 automatically apply  to  all  other plants.   Any manufacturer has an
 opportunity,  as provided  in Subpart  K,  to  demonstrate  that the
 suspension order should not  apply  to other  plants.   §86.1012(1)
 allows  a  manufacturer to request a'hearing for a suspension under
 §86.1012(e).   §86.1014(a)  states  that hearings  are applicable to
 requests  under  §86.1012(1).   S86.10L4(c)(2)(ii)(B) states, in
 pertinent  part, that when a. hearing is  requested  under §86.1012(1),
 the  issues  will be restricted to proper conduct of tests and
 proper  application  of  sampling  plans,   specifically,"...whether
 there  exists a  basis  for distinguishing LDTs  produced  at plants
 other than the one  from  which LDTs  were selected for testing which
 would  invalidate  the Administrator's decision under §86.1012(e)".
 EPA  has therefore made  no  change to  this  paragraph  in  the final
 rule.

      28.   Failed vehicle report  (§86.1012(i)(2)).

     EPA  proposed  that   the report  on  corrective testing  of those
vehicles that failed emission testing during  an SEA be submitted to
EPA "...within 5 days after, completion  of  testing..."-  GM proposed
 that the 5 day requirement be deleted in order to provide a reason-
 able period  of time to the manufacturers and  for  comparability with
the  LDV SEA requirements.   To clarify  its intention, EPA has
revised this  paragraph  for  the  final rule to read "...within five
working days after  successful completion  of  testing on  the failed
engine or  vehicle...".   While EPA needs  to receive reports on the
repair of  noncomplying LDTs in a timely fashion, corrective action
need  not  be  taken  immediately  after  a   failure,  so long  as  the
manufacturer does  not  attempt to  introduce a failed LOT  into
commerce.

     29.  Qualifications of a  Judicial   Officer (§86.1014(b)(5)
          (iii)).

     GM proposed that this paragraph be amended  to ensure  that the
Judicial Officer (J.O.)   is a  graduate  of  an  accredited  law school
and a member of  a bar association.

     EPA does not  take  issue  with  GM's  proposal  and has  incor-
porated it into  the  final rule.
                             UV A

-------
I.   Issue:  Nonconformance Penalty

     This  issue concerns the  system for  production compliance
auditing (PCA)  and  nonconformance  penalties (NCP)  proposed  in the
NPRM.   Since  the proposed emission standards  were considered
feasible for  all manufacturers to  meet,  nonconformance  penalties
were not made available in the  NPRM.

     As described elsewhere  in this  Summary and  Analysis of Com-
ments  (see  G.    "Technological  Feasibility"), the  EPA staff still
believes that  the  standards are attainable  by  all manufacturers.
However, EPA has  decided  not to finalize nonconformance  penalties
at this time.   The  possible  need  for making nonconformance  penal-
ties available  and  their  role  in the  compliance  process  is still
under review by  the Agency.  These matters  will be the subject of
separate rulemaking  by EPA.  Therefore, comments received on these
aspects of  the  NPHM  will not  be dealt  with at this time.

     Delaying final  action on PCA/NCP  does not adversely affect the
mnufacturers'  ability  to  comply with  the regulations finalized in
this present rulemaking.    With or without  PCA/NCP, it   is EPA's
intent   for  all  manufacturers to comply with the  standards.   NCPs
are  not to be  viewed as  a route  to a less stringent emission
standard via intentional design  to  a higher  emission rate  and
payment of  the  associated  NCP.

-------
J.   Issue:  Diesel Crankcase  Emissions Control

     1.    Summary of the Issue

     The proposed  regulations  require  that  no crankcase emissions
shall be  discharged  into  the ambient  atmosphere  from  1983  model
year (and later) light-duty truck diesel  engines.

     2.    Summary of the Comments

     The  proposed  crankcase  controls  for  diesel  LDTs drew  con-
siderable adverse reaction.  Both EPA1* justification and feasibil-
ity issues were addressed by most of the  commenters.

     Several  comments  pointed to  the  low  hydrocarbon  and  carbon
monoxide emissions from light-duty diesel crankcases as evidence of
a  lack  of need for  controls.   Additionally,  commenters  felt  that
the information quoted  in  the  NPRM  is inconclusive in establishing
the presence of nitrosamines in diesel blowby  emissions.

     The  feasibility of  controlling  the crankcase  emissions  was
challenged on the basis that some light-duty diesel engines will be
equipped  with turbochargers.    The  anticipated  technical  problems
arise  from the  oily nature  of the blowby emissions which  in a
simple  system would be introduced  into  the  inlet air supply.
Although  in  a naturally-aspirated  engine  the  slight negative
pressure of the manifold can  draw crankcase fumes into the combus-
tion  chamber,  the manifold of  a  turbocharged  engine is under
greater  pressure  than  the crankcase.    Thus,  unless it  is  pres-
surized, the  blowby must enter  the  stream on the inlet side of the
turbocharger,  allowing  the oily  emissions  to  become deposited on
the compressor wheel.   It  was  indicated  that  this will result in a
decrease in turbo-efficiency which can detrimentally affect perfor-
mance, fuel consumption, and emissions.

     Cummins  Engine  Company  mentioned  four  means of crankcase
control which may have potential.  None are  developed to the extent
of  assessing  their feasibility.  These four  alternatives  are:
                      I
     1)    Duct  gases  to turbo-inlet by way  of a pressure regulator
and oil separator.

     2)   Draw gases through the regulator and separator and a pump
to  the  manifold downstream of the  turbo  (an expensive alternative
which still requires much  development work  to ascertain whether it
is satisfactory).

     3)   Aspirate and mix gases into the exhaust  flow.

     4)    Pump the gas  through  the regulator and a separator into
the exhaust stream.

-------
     3.   Analysis of the Comments

     All but a fraction of the light-duty diesel engines currently
being  produced  (for  both LDVs and  LDTs)  have  crankcase controls;
however, such  control  is not required by regulation.   Regulation
was proposed in  order  that crankcase  control be  maintained  in  the
future and so  that  parity  would  exist  between  the diesel  and
gasoline engines.  Although  the  number of diesel LDTs is small at
this  time,  it  is  anticipated that  the number will  grow substan-
tially with time.

     The majority  of commenters  saw no  major  problems associated
with  the  control  of  crankcase  emissions  in  naturally-aspirated
diesel engines.   The  turbocharged  engine,  however, was quite
another  matter.    EPA  received   a  number of  comments essentially
stating that there are  technical  problems  associated with crankcase
emission control  of  the turbocharged diesel,  and  that overcoming
these problems  could  be relatively costly.  A possible solution  was
recommended by Cummins  (Suggestion  #2  in  Summary of  Comments)  and
seems to be worthy of investigation.  By allowing the turbocharger
to be  bypassed,  the  oil separator/pump/pressure  regulator config-
urations would eliminate the excessive deterioration  of the compo-
nent  efficiencies.  The pump itself might be  affected to some
degree  by  the  oily  emissions;  therefore, further analysis would
have to be  performed.

     Some  commenters  suggested that ducting  the  gases to  the
turbo-inlet by  way  of a pressure regulator and oil separator
(Cummins Suggestion #1) may  be the  easiest and  least  costly of  the
possible crankcase control methods.  It was noted by the commenters
that  even   though this method  seems  viable  there  are problems
related to  the  oily emissions which  can deposit and build up on  the
compressor   wheel  causing a  reduction  in  turbo-efficiency,  fuel
economy, and durability.

     Contrary to  the  conceptual arguments  of  the  manufacturers,
however, is a concrete  example of crankcase control of a production
turbocharged diesel  engine.    Mercedes-Benz,  for  some  time  now,
has been producing  a  light-duty diesel  vehicle that  is  equipped
with  a  turbocharger  and  crankcase emission  controls.    In their
design,  the engine  blowby  gases  and the crankcase vapors flow
through  a  vapor  line in the cylinder head  to  a cyclone separator
located  in  the  air filter.   The gaseous  content of  the crankcase
emissions is drawn off  the separator by the intake manifold vacuum;
the fluid  content  is routed  back to the  oil pan.   In an effort ito
gain  further  information regarding  their design  (essentially
Suggestion  #1 by Cummins) the Staff at ECTD made telephone contact
with Mercedes engineers.  The staff  learned during the conversation
that Mercedes has had no problems to date with their  deisgn and in
addition did not  foresee any  further  problems  such as significant
drops  in turbocharger efficiencies.   Obviously,  such a method
must be  practical  and  not  be overly burdensome  since it is being

-------
done  without imposing regulations.   We realize that there  may
be  differences  between  light-duty truck  and  light-duty  vehicle
diesel engines,  but the staff believes these differences to be  few
and relatively minor.  Therefore, the staff must conclude  that  the
proposed diesel crankcase emission control standard is  technically
and economically feasible.

     4.   Staff Recommendation

     The  staff,  after careful  consideration,  recommends  that  the
proposed  crankcase  emission  standard  for diesel  light-duty trucks
remain unchanged.

-------
K.    Issue:  Numerical Standards/Standards Derivation

      1.   Summary of the Issue

      EPA has proposed new emission standards for light-duty trucks:

      0.8 g/mile HC
      10 g/mile CO

These  standards  are  derived  from emission  tests of  uncontrolled
1969 model year light-duty  trucks.   These  emission tests  data  were
used  to  calculate  a  baseline  from  which the  proposed  HC and  CO
standards were derived.   The 1969 Light-Duty Truck  Test  Procedure
(Title 40,  CFR,  Part  86, Subpart  B) was used to obtain  the emis-
sions data.

     EPA is  proposing  that  the  current NOx standard of  2.3 g/mile
be retained for 1983 and later model  years.

     2.   Summary of the Comments

     The majority  of  the comments were directed  at  EPA's develop-
ment of emission  standards  in Technical  Report  SDSB-79-23 entitled
"1969 Light-Duty Truck Baseline  Program and 1983 Emission Standards
Development.   Commenters contend that  improper mathematical  and
engineering practices  were employed to develop the LDT  baseline and
proposed emission  standards.   Specifically, criticism of the  test
program and standards  derivation were:

     a.   Eighteen vehicles  were too  small a sample.

     b.   Vehicle  stratification  was  inadequate.  Only 1  Chevy 307
was tested, while 4 Chevy 350's  were  tested.

     c.   The  vehicles  were  unrepresentative  since all  vehicles
came  from  San  Antonio,  Texas  area and had mileages  much  less  than
new proposed useful life and represented only 84 percent  of the LDT
market.

     d.   The  pre-test vehicle maintenance was  improper  for estab-
lishing the baseline.

     e.   Deterioration  factors   should  have been  calculated   and
applied to the baseline and  standards.

     f.   Sampling error should  have  been recognized  in calculating
the standards.                                               ,   ,
                                                            /
     g-   Standards are  more  stringent as  a  result  of other .ele-
ments  of  the  NPRM such as  allowable maintenance and  durability.

     3.   Analysis of  the Comments

     This  section  is  divided  into   two  Subparts.  First, EPA's
discussion  relating  to  the final  1969  LDT baseline  emissions

-------
results  is presented.   Second, the  comments on  the issue  are
analyzed.

     a-   Final 1969 LPT Baseline Emission Results

     This section  updates  and  summarizes  the  final  1969  LDT base-
line  emission results.  These  results were  obtained under  EPA
Contract No.  68-03-2683 with EG&G,  Inc.  The  initial baseline
results  which  appeared in SDSB  Technical Report  No.  79-23,  "1969
Light-Duty  Truck  Baseline  Program and  1983  Emissions  Standards
Development",  July 1979, are  shown in Table  1.

     These baseline  results  were used  to calculate  the light-duty
truck HC  and CO  standards,  proposed  on July 12,  1979,  in FR, Vol.
44,  No.  135.   Subsequently,  EG&G discovered that  some of  the
vehicles were  tested without having had  all  the  carburetor  main-
tenance  performed  (letter  of 9/8/79, EG&G to  Mr.  Larry Ragsdale).
As  a result,   all vehicles  were rechecked and  proper carburetor
adjustments were made to the vehicles where necessary.   Any vehic-
les that needed adjustment were retes'ted.

     Table 2  shows  the final corrected  emission  test  results  for
the  18 vehicles included in  the baseline report  cited above.
Ten  vehicles  of  the  eighteen  used  to calculate  the proposed
1983  light-duty  truck  HC  and  CO standards  were  retested.   Addi-
tionally, Table  3  summarizes  emission  data  for  all  1969  light-
duty trucks tested under EPA's  baseline program.   Included in this
table are emission results from an additional three vehicles (#617,
#621,  #623) that  were not  part of  the original sample used to
determine 1969  light-duty truck  baseline  levels  (refer  to  Table
1).  These additional vehicles  were tested after the 1969 baseline
levels had  been  determined  and  included  in  the 1983 Light-Duty
Truck NPRM.

     Table 4 summarizes the sales-weighted emission results derived
from  the various test samples   (Tables 1, 2, and  3).  Table  5
presents the emission  levels that represent a 90 percent reduction
from the baseline  levels  in  Table 4.  Clearly, the retesting would
have resulted  in lower HC and  CO proposed standards (representing
the Clean Air Act's  mandated 90  percent reduction).   The inclusion
of the three additional vehicles would have further  reduced the HC
standard.

     The  staff  recommends retaining  the  standards  (0.8  g/mile HC
and  10  g/mile  CO)  proposed  in  the LDT NPRM even though  they  are
higher than standards calculated  from EPA's  21  vehicle  sample.  The
proposed  standards  represent an 88 percent reduction  in  HC emis-
sions and an 87  percent reduction in CO  emissions as measured from
the final 21 vehicle baseline.   Since these values are  close to the
desired 90 percent reductions,  the staff  considers this action as a
reasonable option  to follow.   To repropose  the standards  at lower
levels would  delay  implementation of  the  rulemaking  while making
only small environmental gains.

-------
                                                       Table 1
                                                L.U.T.  bAStLlNfc  EMISSION RESULTS
                                                                                       02-07-80  09:27:05
1
2
u
<<
5
6
/
ft
9
10
11
12
1J
Ib
lo
17
DODGE
DODGE
DODGE
FOWL
rum,
F Oftl.'
FURU
Crttv
CnEV
CnFV
Cn£\<
CntV
GMC '
Gift
225
22b
318
3lh
302
3bO
160
360
360
360
360
2bO
307
3bO
3bU
3bO
350
404
41d
444
618
610
4?J
613
441
607
450
419
427
602
* LOT
2.20
1.20
3.30
3.30
7.10
24.20
24,20
24.20
24.20
24.20
24.20
9.40
28. '»0
7.80
7. HO
7.. SO
7.80

/
/
/
/
/
/
/
/
/
/
/
/
/
/
/

2
2
2
1
6
b
6
6
6
6
1
1
4
<*
4

s
X
-
s
s
=
=
=
s
It
1.1(10
1.100
1.6SO
1.050
7.100
4.033
4.UJ3
4.033
4.0.J3
4.033
4.033
9.400
2d.400
1.950
1.950
1.950
1.9bO
UTIAL &A!
CORK.
1 	
K32
U99
8.54
4,8b
4.tib
4.8b
11.31
34.18
2.35
2!3b
2.35
5EL1NE DATA
7.651
5.736
7.856
H.440
7.993
11.667
10.663
5.177
6.969
7.963
2.946
4.374
9.111
13.844
7.767
7.188
8.623

0.101
0.076
0.1S6
0.22H
0.683
0.566
O.blrt
0.2S1
0.3Jd
0.386
0.143
0.495
3.114
0.325
0.182
0.169
0.202

70.070
158.213
Bb.976
102.562
141.764
203. Ib7
2H.724
77.388
63.785
60.709
44.556
57.264
95.517
90.393
149.356
100.387
106.630


0.928 5.488
2.094 2.328
1.707
2.036
12.112
9.860
10.665
3.756
3.096
2.947
2.163
6.478
32.650
2.121
3.505
2.356
2.502
4.354
3.918
1.733
2.309
1.673
4.974
5.054
2.904
2.767
4.546
3.618
3.389
2.140
2.818
3.155
0.073
0.031
0.086
0.078
0.148
0.112
0.081
0.241
0.245
0.141
0.134
O.S14
1.236
0.080
0.050
0.066
0.074
18 JrtC
34b   faUl
0.70 / 1
0.70U
0.84
14.742
0.124   155.920
1.313
1.958
0.016
                                             83.100  100.00
                                                      8.058
                                                           102.29
                                                                    3.408
PROGRAM NAME: SGwK57140C-LOT

-------
                                                       Table 2
                                           19o9 L.O.T.  HftStLlNE EMISSION KF.SULTS
                                 02-07-60  09:38:22

1
2
3
4
5
6
7
8
10
11
12
13
It)

OODGt*
OUDOE
OOO&E
OOnCE
FORD
r OHi)
FOPO
FUPU
FOHU
rOPO
FGHD
CnEV
V
CMEV
CMFV
CHF.V
CnjiV
GMt
i
1HC
I
*
Ql!2
~225
225
31H
302
360
360
360
360
360
360
250
.307
350
3SO
350
3bO
345
* LOT
Ji£H2. SiLLS 	
42«
4<»4
61B*
421
425
491*
610*
H41*
607
419
<*SO*
602
001*
2.20
2.20
3.30
3.30
7.10
24.20
24. ?0
24.20
24.20
24.20
24.20
9.*0
26. 40
7. HO
/.<*<>
7!(JO
0.70
/ 2 =
/ 2 =
/ 2 =
/ 2 =
/ 1 =
/ e =
/ 6 =
/ 6 a
/ 6 =
/ 6 =
/ 6 =
/ 1 =
/ I =
/ 4 =
/ 4 =
/ 4 =
/ 1 =
1.100
1.100
1.650
1.650
7.100
4.d33
<».033
4.033
4.033
4.033
4.033
y.tOO
24 .'•00
1.950
1.9SO
1.950
1.950
0.700
WITH HETE
CORK.
> 	
1.32
1.32
1.99
1.99
tt.34
4,a5
4^85
4.d5
11.31
3^.1
-------
 1  OOUGE
 2  DODGE

 3  DODGE
 4  OOOGE

 5  FORD
 6
 7
   FORD
   FUKLI
 8 FORi)
 9 FOHO
10 FOWL)
11 FORD

12 CHEV
1J CHKV

14 CHEV

Ib CHEV
16 CriEV

17 CMEV
Id CHEV
19 CriEV
20 GMC

21 IHC
                                                     TAbLE 3

                                           1969 L.D.T. BASELINE EMISSION HESULTS
                                                                                                            02-19-80  09(42117
CJJi
225
225
316
31H
302
360
360
360
360
360
360
2bO
2bO
292
307
307
350
350
3bO
3bO
345
JitUi .
404
418
444
618
421
425
473
491
610
613
623
617
607
621
419
427
4bO
602
601
* LOT
SALES
if. 20
2.20
3.30
J.JO
7.10
24.20
24.20
24.20
24.20
24. 20
24.20
9.40
1.60
28.40
26.40
7.80
7.80
7.80
7.80
0.70

/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/

2
2
2
1
6
o
6
b
6
t>
2
2
1
2
2
4
4
4
4
1

=
=
=
s
s
s
s
s
s
a
s
=
/
1.100
1.100
1.650
1.650
7.100
4.033
4.033
4.033
4.033
4.033
4.033
4.YOO
<*.700
1.600
14.200
14.200
1.950
1.950
1.950
1.950
0.700
kLL VfcHICl
COR*.
* 	
1.30
1.30
1.95
1.95
6.38
4.76
4.76
4.76
4.76
4.76
4.76
5.55
5.55
1.69
16.77
16.77
2.30
2.30
2.30
2.30
0.83
.ES
4.238
7,651
7.656
11.480
4.096
7.963
2.946
4.547
5.294
b.92b
5,942
3.910
7.516
10.345
9.111
5.128
7.767
6.789
7.628
8.623
7.612
•

iAL£=a!fi
0.055
0.099
0.153
0.224
0.343
0.379
0.140
0.217
0.252
0.330
0.283
0.217
0.417
0.195
1.527
0.860
0.179
0.156
0.176
0.199
0.1)63

86.072
70.070
85.976
102.562
69.613
60.709
44.556
65.038
77.663
116.007
67.867
27.438
62.402
83.903
95.537
56.641
149.356
70.528
144,841
106.630
106.287

SALEzMIC NQq-ttTP SAL£rMI2
1.118 6.380 0.083
0.910 5.488 0.071
1.675
1,998
5.835
2.691
2.122
3.097
3.698
5.619
3.232
1.523
3.463
1.585
16.017
9.496
3.439
1.624
3.335
2.455
0.695
4.354
3.918
3.267
2.904
2.767
4.862
5.780
5.382
5.139
4.89b
3.421
3.717
3.616
3.231
2.140
2.825
2.365
3.155
2.272
0.065
0.076
0.274
0.138
0.132
0.232
0.275
0.256
0.245
0.272
0.190
0.070
0.607
0.542
0.049
0.065
0.054
0.073
0.019
                                             84.700  100,00
                                                                           6.464
76.025
3.307
PROGRAM NAME: SGWK:7140C-LOT

-------
                             Table 4

                   Sales-Weighted Emission Results

Data           Sample Size     HC (g/mi)      CO (g/mi)      NOx  (g/mi)

Initial Test       18            8.058         102.29           3.408
Results (be-
fore retesting,
Table 1

Initial Test       18            6.866          80.542         3.958
Results (after
retesting,
Table 2

Final Test         21            6.464          76.025         3.807
Results (in-
cludes all
vehicles  tested,
Table 3)

-------
                              Table 5

                  90 Percent: Reduction from Baseline
                           HC and CO Levels
     Data
Sample Size
18
(HC g/mi)
0.8*
CO (g/mi)
10*
Initial Test
Results (Table 1)

Initial Test            18              0.7                8
Results after
Retesting (Table 2)

Final Test Results      21              0.6                8
(Table 3)
*    These levels were proposed as 1983 emission standards for
light-duty trucks in July, 1979 (FR, Vol. 44, No. 135).

-------
     b.    Comment s

     Many of  the issues concerning the LDT baseline  program  were
previously raised  in connection with  the 1984 heavy-duty  engine
gaseous  emissions rulemaking.   These  issues are analyzed  in  depth
in the  Summary  and  Analysis  of Comments document  accompanying  the
final heavy-duty rulemaking, and to  the extent  relevant,  are
incorporated herein by reference.   Because of this, the issues  will
be treated breifly here,  and  the reader is  referred  to  the  heavy-
duty document for further discussion.

     MVMA and the  manufacturers  criticized  the  light-duty  truck
test  program's  sample size of  18  vehicles  as being  too  small  to
formulate an accurate  baseline.   The staff disagrees.  EPA's
rationale for using  18  vehicles was  based  on  two considerations.
First,  the   sales-weighted  emissions  after 18  vehicles had  been
tested  were   leveling off  at  essentially constant values and  EPA
believed  that further testing would  not  significantly  change  the
baseline.   Second,  the emission 'results obtained  from the  18
vehicles agreed favorably  with  the previous emission results
obtained  from other EPA test  programs for 1969 light-duty trucks.
This rationale is further discussed in  the report  "1969  Light-Duty
Truck Baseline   Program  and   1983  Emission  Standards  Development"
contained in  the docket.

     Tables  6 and 7  show that  after  testing  only 8  vehicles,  the
emission  results began  to stabilize.    (NOTE:    these  are  plots of
the  18  vehicles' emission results before  retesting  of  10  of  the
vehicles).

     The baseline results after retesting  are:

     6.87 g/mile HC
     80.54 g/mile CO

     Three additional vehicles were  tested after  issuance  of  the
NPRM.   Inclusion of  these three vehicles  reduced  the baseline by
less than 6  percent  (see Table  3).  Thus, final baseline emissions
for all 21 vehicles tested at EG &  G are 6.464 g/mile HC and 76.025
g/mile  CO.   Inclusion of sales-weighted emission data from 11 LDTs
from  other  EPA  programs  (see Table  8) yields baseline values  of
6.53 g/mile  HC and  74.55 g/mile CO for  the 32-vehicle sample.  The
values  for the  32-vehicle sample are  5 percent  lower for  HC and 7
percent lower for CO  than the 18-vehicle sample.

     The  pertinence  of constructing this 32-vehicle composite
baseline is  to show that the  18-vehicle baseline results  are
reasonably  close to the 32-vehicle baseline results.  Nearly
doubling the sample size had minimal effects  on the baseline
results (i.e., 6.87 g/mile vs. 6.53 g/mile  for HC).

     The  second  consideration was the  agreement  between  previous
1969 LDT  emission test  data  and the  baseline  emissions  data.  The

-------
                 Table 6
LOT SflLES-WEIGHTED BRSELINE
EMISSIONS    HC-(GRRMS/MI)

-------
                      Table 7
 I
 C.
 o
 CJ
 3
R


§
—
o
o
o
LOT SflLES-HEIGHTED  BflSELINE

EMISSIONS    CO(GRRMS/MI)
                          -c—
           4.CO
               8.CO
lira

-------
                                              Table 8
H69 L.O.T. riASELI'Nc
                                                             N Uc.SULTr>  -  COMPUSlTc! i)ATA
02-22-60  14:09:33

Vf H 1 .-1 I."
i r.u'-iijc
2 DOOGF
3 DODGF:
H CODGF.
•= FOPD
t FUPO
7 fUPO
H F0"0
^ FOO
il F'.'-^i
11 F : J r" 0
i .•: r" 0 -' "
13 i'J-'U

1-a r'Jr-0
16. F'JPO
; 7 ~ H '-' \i
U TnKV
1^ CrtKV
20 GM
': rn<-v
22 C"FV
2J f-f,
2* CMfc'V
2S Cr<£V
2o CHrlv

2'-> r-vc
,>'/ ,',v,C
30 r,."!C
31 GMC
J2 IMC

CiD '
225
225 .
318
3 lr,
2*0
302
360
J60
3 b'.1
360
3 60
36-J
JoO
360
36u
3 si;
25 n
•in.*
292
2v?.
30V
-j , j /
:>.../
3bO
3t>ii
3:>u
3bO
150
3-0
3^0
396
345

JFM"
404
428
4lft
4*4
8
018
421
•s,'-:5
-+73
4^1
blO
oi3
3
7
10
i*
4^1
t>2 .1
617
6
607
••>2i
12
*L9
427
Hr.il
602
1
2
11
9
601
, 1 M T
s HJ 1
2.20
2.?0
3.30
3.30
5.90
7.10
^4.20
^4.20
ir* .20
? 4 . ',1 'J
/.'• .2 u
2;>.2lJ
£<* .20
24.Pii
24.20
J.SO
•y.v.i
v.*j
1.60
1 .60
/-O .*'!
2-.: .'»!'
2b.nO
l.H(j
/.80
/.d'J
7.40
7.30
7.80
7.hO
0.80
0.70


/. 2 =
/ 2 =
/ 2 =
/ 2 =
/ 1 =
/ 1 =
/ 9 =
/ 9 =
/ •* •=
/ -y -
/ 9 =
/ 9 =
/ 9 =
/ 9 =
/ 9 =
/ I =
/ 2 =
/ 2 -
/ 2 =
/ 2 =
/ 3 -
.' 3 =
/ 3 =
/ 7 =
/ 7 =
/ 7 =
V —
/ 7 =
X 7 =
/ 7 =
/ 1 =
/ 1 =


1.100
1.100
1.6SO
l.o'^O
5.^00
7.100
4,.f,HS)
<^. t>89
2.t- 89
2.^i9
^ . fc 'j •>
2.oc9
£f . 6 J5 9
2.6H9
2.tWjy
3.500
4.700
4.700
0.800
O.hOO
9.4^7
9 . * "i 7
9.*b7
1.114
1.114
l< ;i4
1.114
1.11*
1.114
1.114
0.800
O./OO
C (\'rJ-/
^ltf\f< •
.*
1.16
l.lo
1.74
1.74
6.2J
7.48
2.rt3
2.83
2 . B 3
2 .^3
2.o3
2.«J
2.aJ
2.rt3
2.-»3
3.^,9
4.95
4.9b
O.b*
0.8*
9.96
9,^a
9.9B
1.17
1.17
) . 1 7
1.17
I. It
1.17
1.17
O.ti*
0.74
<•— r*

(ULibiriilti iALL-v.-TQ
4.23b
7.6^1
7.856
11 .480
6.8^0
4.096
7.963
2.9*6
*.•?* 7
S.?9*
0.9^5
5. s^«+2
4.530
8.0*0
12.4^0
t . 3 1 0
3.910
7 . b ) 6
10.345
6. >MO
9.111
5. 128
0.220
7.767
0.769
7 .62tt
tt . r> Z 3
4.9.40
9.000
9. /30
7.070
7.612
0.049
0.089
0.137
0.200
0.428
0.306
0.226
0 . ("• 8 3
0.129
0. ISO
0. 19o
0 . 1 68
0.1 2M
0.228
0.354
0. 159
0.194
0.372
0.08f
0.052
0.909
0.512
O.o<:0
0.091
0.080
0.090
0.101
0.058
0. 106
0.114
0.060
0.056

NON-iTQ 5
86.072
70.070
«5.976
102.562
114.970
69.613
60.709
4*. 556
6b.038
77.663
118.007
6/.H67
S6.000
103.500
106.460
54.480
27.43*
t>2.402
83.903
68.390
95.537
56.641
31.490
149.356
70.526
144. M*l
106. 63u
89.240
113.^00
Ib2.730
83.440
108.267

iM.t-«TO
0.99ft
0 . ft 1 2
1.49S
1.783
7.148
5.208
1.720
l.?62
1.&43
2.200
3.3*4
1.923
1.5H7
2.933
3.016
2.009
1.359
3.091
0.707
0.577
9.53"
5.650
3.141
1.754
0.8?H
1.701
1.252
1.048
1.334
1.793
0.703
0.799

• ii2lir iili 5 A i. K - w T o
6.380
5.*oB
4.354
3.91*
5.40o
3.267
2.904
2.7t>7
4.io2
5. 7rjO
5. Jo2
b. 1 34
4.1*0
2.H10
6.960
8.460
4.69-j
3.421
3.717
4.810
3 . n 1 8
3.^31
7.^HJ
2.1*0
2.i25
2.365
3.155
7.030
5.060
S.4SO
7.060
2.272
0.074
0.064
0.076
0.06ft
0.336
0.244
0.032
0.07H
0 . 1 3S
0. 16*
0.1S?
0.1*6
0.117
0.080
0.197
0.312
0.242
0. 169
0.031
0,041
G.jM
0. 3^^
0.722
0.025
0.033
0 .028
(i . 0 3 7
O.u33
0.. 060
0.06*
0.060
0.017
                                   v*.900  100.00
                                 6.S32
                                                                                     74.548
                                                                          4.623
?: SGwK:7140C-L!)T

-------
                                              Table  9
Estimated
No.
1
2
3 '
4 .
5 •
6
7
8
9
10
11
12
Manufacturer
General Motors
General Motors
Ford
Ford-
Dodge
General Motors
Ford
Ford
General Motors
Ford
General Motors
General Motors
1M9 Lieht Dutv Truck-Baseline .
Engine
350
350
360
390
383
292
360
240
396
360
350
307
tn3
in3
in3
in3
in3
in3
t»3
in3
in3
in3
in3
in3
•(6,000 - 8,500 GVWR)
Inertia Road
5000
•5000
• • 4500
. 5000
5000
5500
5000
' 4500
5000
5000
..5500
• 5000
Ibs' ' '
Ibs •
Ibs
Ibs
Ibs
Ibs
Ibs .
Ibs
Ibs '•'
Ibs
Ibs '.
Ibs
Average
17.9
17.9
13.1
17.9
17.9
22.7
17.9
21.8
21,1
21.1
22.7
17.9
•MMMMMV-V
19.2
Load
hp.
hp
hp
hp'"
hp
hP-- :
hp '
hp
hp
hp '
hp
>
•
Metric (g^kmj
Emissions g/mile
HC CO ' NOx
.'4.94
'9.00
4.53
4.31
8.54
6.18
8.04
6.89
7.07
12.49
9.73
6.22
.'7.33
4.55
• 89.24
• 113,
56.
54.
149.
\ 68.
103.
114.
83.
106.
• 152..
31.
• 93.
58.
60
00
48.
00
39
50.
97
44
46
73
4.9
61
17
7.03
5.08
4.14
8.46
9.12
4.81
2". 81
5.40
. 7.06
6.96-
•5.49
7.24
6.13 '
3.81
Sources:  A Study of- Baseline Emissions on 6,000-14,000 Pound Gross Vehicle Weight Trucks,
          June 1973, Automotive Environmental Systems, Inc., APTD-1572, (Vehicles 1 to 5)

          Baseline Emissions on 6,000 to 14,000 Pounds Gross Vehicle Weight Trucks, June, 1973,
          Southwest Research Institute, APTD-1571 (Vehicles 6 and 7)

          Medium Duty Baseline Tests, Environmental Protection Agency, Unpublished (Vehicles 8 to 12)

-------
 sales-weighted  baseline  results  for  the  initial  tests of  18  ve-
 hicles  (Table  1) are 8.06 g/mile HC and 102.29 g/mile CO.   This is
 close to the average emissions (7.33 g/mile HC, 93.61 g/CO) for 12
 vehicles tested previously in EPA programs (Table  9).  The revised
 baseline  results  agree  even  more  closely  than did  the  original
 baseline data.

     Commenters criticized the vehicle sampling plan for inadequate
 stratification.  They cite that only 1 GM 307 (28.4 percent of LDT
 sales) was tested while 4 GM  350's  (7.8 percent of LDT sales)  were
 tested.  EPA originally,  because  of  the sales data available, set  a
 target  number  of  GM 350's  to be tested  at  2-3.   Later  this  was
 revised to two GM 350's when more accurate sales data was  provided
 by the manufacturers. Since 4 vehicles were already procured,  they
 were included.

     Regarding  the  GM  307, EPA's  original  target goal was  seven
 engines, however only two were finally obtained.   This  was due to
 our inability  to  locate  more  engines.  Only one  of  these engines
 was tested at the time the original baseline testing  was completed
 for the  NPRM.   The  second  307 was tested  subsequently,  and  that
 data is included in Table  3.

     In evaluating the  adequacy of  the samples  tested  for  in-
 dividual  families  it  is important  to bear in mind the  sales-
weighting process used  by EPA to determine  the baseline  emission
 rate.   In that process,  the emission  results from each engine
 are weighted  to  account  for the  fraction  of sales  which  the
 subject  engine family  represents.   Because of  this, it  is  not
 in any  way necessary  for the number of engines  tested  in each
 family  to also  be sales-weighted.   A  baseline could  just as
well be computed from a sample containing equal numbers  of engines
 from all families.   The reason why EPA desired to  sales-weight  the
 sample of engines  procured was to obtain the most accurate  data  for
 the most  important  (in  terms  of sales) families with  the minimum
overall number  of engines.   Failure  to be completely  successful at
 this goal does  not  invalidate  the baseline process.

     MVMA contends  that  the  sample vehicles  are  unrepresentative
 since: 1) they were all procured from the San Antonio, Texas area;
 2) the mileages were much less than the  new proposed useful life;
and 3)  the 18-vehicle  sample represented ony  84  percent of  LDT
 sales.

     The  staff disagrees  with this assertion.    The vehicles
 selected  for baseline  testing were  1969 model  year light-duty
 trucks which had received  no  major  engine overhaul  and which  had
original carburetors and distributors  in  most  cases.   In addition,
 the vehicle selected had  to pass selection criteria aimed at
obtaining vehicles  in  good  mechanical condition.   Pre-test main-
tenance  assured  that the  vehicles  were  representative.    Speci-
 fically, engines were tuned to manufacturers  specifications in an
effort  to  preclude  uncharacteristic  emissions  caused  by out of
                              13;

-------
 spec,  engines.   Defective  components  were  replaced  in some  in-
 stances.   Accordingly  the pre-test maintenance  normalized  the
 vehicle  sample.  MVMA has  presented no  reasons  why emissions  from
 well maintained  vehicles  would have significant geographic vari-
 ability.

      Commenters were critical of the test vehicle mileages  because
 they were  less  than the  proposed  useful life definition.   EPA's
 goal in  formulating  a baseline has been thoroughly discussed in the
 Analysis  of Comments to  the heavy-duty 1983  gaseous emissions
 rulemaking (issue M).   In summary,  all  efforts were made to insure
 that only mechanically  sound  engines with  original equipment  were
 used in  the baseline to  accurately reflect 1969 engines.  Practical
 limitations then resulted  in  low-mileage applications being  prefer-
 entially selected.   In-use deterioration of  we11-maintained vehi-
 cles is  inherently  low (see discussion below), so that no important
i mileage  related effect will occur.

      MVMA criticized the  18  vehicle sample even though  it  repre-
 sented  nearly 84 percent of  light-duty truck  sales.   EPA believes
 that 84  percent is a reasonable figure  for  determining a baseline.
 The emission results for 21 vehicles  tested  at  EG&G are 6.464
 g/mile  HC and  76.025 g/mile  CO  and  represents  84.7 percent of the
 LOT sales (6001-8500 Ib. GVWR).  EPA's 32 vehicle sample results in
 emissions of 6.532  g/mile  he and 74.548 g/mile  CO and represents
 94.9 percent of the  LDT  sales.  The difference in emissions  between
 the two  baselines is minimal.

      Commenters contend  that  the pre-test  vehicle  maintenance was
 improper  for establishing  the  baseline.    Maintenance  should  have
 been limited to only  maintenance  specified  in  the certification
 procedure as defined  in the  new NPRM.   The  staff disagrees  with
 this contention.

      The  maintenance performed on the test vehicles was necessary
 to  assure that  the  test engines were as close  to  new engine  con-
 figuration as possible without  major overhaul.   If  a component was
 so  worn  that manufacturers  specifications could not be met,  then it
 was rebuilt  or  replaced.  However, the most important consideration
 was to tune-up the engines  to  1969 manufacturers  specifications.
 In  fact,  several vehicles  were rejected  after having been procured
 because  major  engine maintenance  was  needed.  The maintenance
 performed was not  limited  to certification specified maintenance.
 the staff believes the maintenance performed was reasonable,
 however,  for 10 year old vehicles.

      Manufacturers   maintained  that  deterioration   factors   should
 have been  calculated  and  applied  to  the  baseline  and standards.
 The staff  disagrees.    Baseline  emissions  were  calculated  to
 represent  the  average  of the actually measured  emissions  from
 1969 model year light-duty trucks.   Since the engines were  charac-
 terized  as new  engines (due to pre-test maintenance) a zero  deteri-
 oration   factor  assumption was  made.    Furthermore,  certification

-------
data  for  non-catalyst  engines  shows  that  these engines have
inherently  low  deterioration  factors,  and support  the  zero d.f.
assumption.

     MVMA and the manufacturers asserted that  sampling  error  should
be  recognized  in calculating  the  standards  and recommended  using
the upper 90 percent confidence limit of  the mean.   The  staff does
not believe that  this  procedure  is required  by the  Clean Air Act.
According to section 202 a(3)(A)(ii) of the Act, the standards  are
to  be  derived "from  the average  of the  actually measured  emis-
sions. "
     MVMA contends that as a result of other elements of  the NPRM,
the standards are more stringent than a 90 percent  straight reduc-
tion.  The  staff  disagrees  with this comment.   EPA is directed to
promulgate regulations  which  will cause at  least a 90 percent
reduction in HC and  CO emissions  as measured from  1969 model year
LDT's.  The other  elements of  the  rulemaking do  not  directly affect
the  stringency  of the numerical  standards,  which  are unchanged.
Rather, they work toward a  fuller  degree of  compliance  with the
standards.   Thus,  they help assure that  the  desired  minimum per-
centage reductions are attained.

     4.   Recommendation

     Retain the new emission standards  as  proposed.

-------
L.   Issue:   Fuel  Economy

     1.    Summary  of the  Issue

     If  adopted  as proposed,  will  the regulations  and  standards
cause  complying  vehicles  to experience  a  fuel economy  penalty?

     2.   Summary  of the  Comments

     In general, most commenters preferred to analyze fuel economy
effects  on  the basis of  40 percent AQL  and  a  50,000-mile  useful
life,  in spite of the proposed  changes.   Bearing  this  in mind,
most  manufacturers considered   the  current  emission  standards  in
California  to be  approximately equivalent   in  stringency  to  the
proposed  standards;  the  impact on  future fuel  economy  was  extra-
polated  from  the  fuel economy performance of  the California fleet.
No fuel economy impact on diesel vehicles  was  claimed.
                                   r
     General  Motors claimed a  one mpg (7  percent)  fuel economy
penalty in gasoline vehicles as a  direct result  of  these standards.
The  addition  of air injection and danger to spark  retard, EGR, and
carburetor  calibrations  to  assist   catalyst  lightoff are  all
strategies currently used  in California which  GM argued would
be adopted Federally to meet the proposed  standard.   No closed-loop
systems are anticipated.

     Ford  claimed  that use of oxidation catalyst,  EGR   and air
injection would be necessary to meet the  standards at a 40  percent
AQL  and  50,000-mile useful  life.   In addition,  the higher  inertia
powertrains  would  require   light-off  catalysts of  dubious dura-
bility.  Overall  fuel economy penalties of 3.4  percent and 7.2
percent  for models  with and without light-off catalysts respective-
ly  were  anticipated.   No projections  were  given  under 10  percent
AQL,  full useful  life conditions.

      International Harvester  claimed that  EGR, additional air
injection, and oxidation catalysts would be  needed.

      Volkswagen claimed  that with  a 40 percent  AQL and  50,000-mile
life,  only EGR and oxidation  catalysts would be   necessary.   (The
lean burn techniques  presently  used permit the  reduction  of NOx  in
the  exhaust  with  only  oxidation  catalysts.)  No  additional air
injection  would  be  necessary.   With 10  percent  AQL,  however,
Volkswagen's preferred  strategy  would  be  the use of three-way
catalyst and  feedback carburetor.  In general, Volkswagen foresaw a
5 percent fuel economy penalty in its  heavier vehicles,  as  opposed
to  some  gains using  three-way  systems  with  lighter  inertia weight
vehicles.

      American Motors  predicted  a  fuel  economy loss of  .4 to .8 mpg
 (40  percent  AQL,  50,000-miles).    No  hardware changes  were  pre-
dicted;  changes  to carburetor  calibrations  would  allow compliance
but result  in the fuel economy  penalty.

-------
     In  public  testimony,  commenters  disclosed under  questioning
that  electronic  engine control  technology  was being pursued, but
refused  to  give  further details  for "proprietary"  reasons.

     3.   Analysis of the Comments

     Since most  commenters preferred  to analyze this issue on the
basis  of the  California  fleet,  the  staff's  initial  analysis of
expected  fuel  economy  impact  will follow  suit.    From there, an
analysis  will  be performed of  the differences between  California
compliance strategies  and  those  strategies  which  the staff  antici-
pates to be used to comply with the 1983 standards.   An  estimate of
the  fleetwide  fuel  economy impact of  these  proposed  regulations
will conclude the analysis.

     Table L-l presents comparative emission and  fuel economy data
for California and Federal  light-duty trucks tested  at  EPA's Motor
Vehicle Laboratory.   In all cases (except where noted),  the  compar-
ative vehicles are identical with the  exception of emission  control
equipment.*  For ease of comparison, the control strategies  adopted
for  California  compliance and  their  impact on the  California
vehicle's  fuel  economy  (or averaged over  all  similar-technology
tests) are presented in Table  L-2.

     Tables L-3 and  L-4 present  data  used in  deriving  the  staff's
projected fuel  economy penalty  for the national light-duty truck
fleet presuming that no new technology  is introduced in  1983.  The
analysis sales-weights  the  penalties derived from EPA certifiation
data in  Table  L-l  with one exception,** and  derives a  fleet-wide
fuel  economy  penalty  based upon  the   projected  market shares of
four, six, and eight cylinder  engines  in 1983.

     The results of  the comparison support the  industry's  conten-
tion that an overall fuel  economy  penalty is likely  if  California-
style technology is  applied.   The staff's  analysis  indicates that
with no technological improvements,  an average penalty of 5.2
percent per manufacturer  was  experienced in California.  This
agrees  fairly  well  with  the  commenters' projections.   The staff
takes strong issue, however, with  the claim that  such a penalty is
unavoidable for compliance with the 1983 standards.
*    Same inertia weight,  transmission,  axle ratio,  and dynamometer
road load horsepower.
**    Some  eight cylinder  engines tested at  EPA's lab indicated no
fuel economy  penalty.   However,  vehicles in higher weight  classes
are certified to  California standards which  are  roughly  equivalent
to  the  Federal  standards,  i.e.,  no reduction,  no applied tech-
nology,  no fuel economy loss.   Based upon GM's  comments alluding to
the fact that air pumps would  be  needed  on eight  cylinder families,
an  overall  penalty  of 4 percent  was attributed  to the  air  pumps'
parasitic horsepower requirements.

-------
                        Table L-l

    Emission and FOB! Economy Data for I.ighc-Duty Trucks
Acquired From EPA's Emission Certification Tests for 1980 MY

Vehicle
Model
Jeep CJS
Jeep CJ7
Jeep CJ7
Jeep CJ7
Jeep CJS
Jeep CJS
Eagle Wagon
Eagle Wagon
Jeep CJ7
Jeep CJ7
Jeep CJS
Jeep CJS
Jeep J20
Jeep J20
Cherokee
Uagoneer
Bl Van
(109" HB)
B100 Van
(109" WB)
B2 Van
(127" HB)
B2 Van
(127" WB)
B2 Van
(127" WB)
W150

HI 50

F-100 Reg.
CAB LWB
F-100 Reg.
CAB LWB
F-ISO SC LWB
F-150 SC LWB
F-250, 4x4 LWB
F-250, 1x4 LW?

F-150, 4x2 LWB
F-150, 4x2 SWB
F-150, 4x2 LWB
F-150, 4x2 SWB
E-250, LHB
Cluhuagon
E-250, LWB
Clubwagon
F-100, 4x2
SWB RC
F-100, 4x2
' SWB "RC
F-100, 4x2
1MB RC
F-100, 4x2
LWB RC



ENGINE
MFC
AMC
AMC
AMC
AMC
AMC
AMC
AMC
AMC
AMC
AMC
AMC
AMC
AMC
AMC
AMC
AMC
Chrysler

Chrysler

Chrysler

Chrysler

Chrysler

Chrysler

Chrysler

Ford

Ford

Ford
Ford
Ford
Ford

Ford
Ford
Ford
Ford
Ford

Ford

Ford

Ford

Ford

Ford

Family
BT6C1
BT9A1
CT4W1
CT3A1
CT4W1
CT3H1
CT4W1
CT3A1
HT3V1
HT3A1
HT3V1
HT3A1
NT3A1
NT3A1
NT3A1
HT3A1
OTA-225
-1-BXP
OTA-225
-1-BCP
OTA-3 18/360
4 BCP
OTA-3 18/360
4 BFP
OTA-3 18/360
4 BFP
OTA-318/360
4 BCP
OTA-318/360
4 BFP
4.9ND

4.9HA

4.9ND
4.9NA
5. OMB
5.0NA

5.0NB
S.ONA
5.0NG
S.ONA
5.0NB

5. ON A

S.OtlC

S.ONA

5.0NG

S.ONA

CID
151
151
258
258
258
258
258
258
304
301
304
304
360
360
360
360
225

225

360

360

360

360

360

300

300

300
300
302
302

302
302
302
302
302

302

302

302

302

302


Fed. or
Calif.
Both
Fed.
Calif.
Fed.
Calif.
Fed.
Calif.
Fed.
Calif.
Fed.
Calif.
Fed.
Calif.
Fed. ,
Calif.
Fed.
Calif.

Fed.

Calif.

Fed.

Fed.

Calif.

Fed.

Calif.

Fed.

Calif
Fed.
Both
Fed.

CjUf.
Fed.
Calif.
Fed.
Calif.

Fed.

Calif.

Fed.

Calif.

Fed.

Additional
Technology in
California
3-way Cacalysc

Light-off
Catalyse
Light-off
Catalyse
Light-off
Catalyse
Increased Cata-
lyst Loading
Increased Cata-
lyst Loading
Calibration

Calibration,
Axle ratio
Catalyst Loading,
Inereia Weight,
Axle Ratio

Light-off Cata-
lyst (Fed.), Cata-
lyst Loading, Iner-
tia Weight, Axle
Ratio

Transmission, Iner-
tia, Axle Racio,
Light-off Catalyst,
Catalyst Loading
Light-off Catalyst,
Axle Ratio


Light-off Catalyst,
Axle Ratio
Larger Catalysts,
Transmission,
Inertia Weight
Larger Catalyst,
Inertia Height
Light-off Catalyst,
Larger Catalyst
Larger Catalyst,
Calibration


Light-off Catalyst,
Larger Catalyst,
Axle Ratio

Manual Transmis-
sion., Axle Ratio,
Lifhc-off Catalyst,
Larger Catalyst

4X
Cert i f icat ion
HC
0.18
0.42
0.43
0.48
0.40
0.67
0.28
0.35
0.38
0.94
0.28
0.73
0.57
0.56
0.56
0.72
0.23

0.58

0.22

0.40

0.46

0.37

u.78

0.23

0.57

0.24
0.87
0.59
0.73

0.42
0.53
0.24
0.58
0.40

0.51

0.22

0.61

0.24

0.59

CO
2.47
5.62
7.39
11.28
4.43
6.35
3.88
7.76
3.90
9.27
2.80
4.87
9.10
11.00
9.90
15.00
1.81

11.00

6.99

8.80

8.10

8.80

14.14

2.10

i.OO

6.20
8.80
4.82
6.92

3.96
9.62
2.10
9.62
6.72

4.13

1.60

7.60

2.00

3.46


Levels
NOx
1.30
1.50
1.00
1.40
1.41
2.00
1.50
2.00
0.92
1.60
1.45
1.70
1.74
1.65
1.94
1.36
1.28

1.60

1.20

1.20

0.94

1.70

1.40

1.90

1.08

1.60
1.86
1.59
1.59

1.42
1.31
1.45
1.31
1.17

1.50

1.45

1.97

1.45

1.78



MFC
21.5
21.4
15.1
15.6
15.4
15.2
15.0
16.4
12.1
14.2
11.4
12.9
10.7
11.0
11.5
11.8
17.1

15.4

11.6

11.4

13.1

11.8

10.8

16.8

16.2

16.0
17.9
12.4
12.8

14.4
14.7
13.5
14.7
11.8

12.5

13.2

16.4

13.0

15.4


Percent
Oi f ference
+0.5

-3.2

*1.3

-8.5

-14.8

-11.6

-2.7

-2.5


+11.0



+1.8


-11.5


»9.3



+3.7


-10.6

-3.1


-2.0

-8.2


-5.6



-19.5



-15.6


                          13 (

-------
                    Table L-l (cont'd)

    Emission and Fuel Economy Data  for Light-Duty Trucks
Acquired From EPA's Emission Certification Tests for  1930 MY

Vehicle
Model

-
Traveler 4x4
Traveler 4x4
Scout II, 4x4
Scout II, 4x4


Scout II, 4x4
Scout II, 4x4

Chevy UJV-1
Chevy LUV-1
Chevy LUV-4
Chevy LUV-4
Deluxe, 5 spd
Pickup
Deluxe, 5 spd
Pickup
Pickup, 5 spd
King Cab
Pickup, 5 spd
King Cab
Pickup King Cab
Pickup King Cab

Pickup Cab
and Chassis
Pickup Cab
and Chassis
D50
D50
DSO
DSO
D50
050
D50
DSO
Courier
Courier
Courier
Courier
Courier
Courier
Land Cruiser
Hardtop
Land Cruiser
Hardtop
Land Cruser
Sta. Sgn.
Land Cruiser
S/W
4-WD Pickup SB
4-UD Pickup 13



ENGINE
HFC
CM
CM
IHC
IHC
me
IHC


IHC
IHC

Isuzu
Isuzu
Isuzu
Isucu
Nissan

Nissan

Nissan

Nissan

Nissan
Nissan

Nissan

Nissan

Mitsubishi
Mitsubishi
Mitsubishi
Mitsubishi
Mitsubishi
Mitsubishi
Mitsubishi
Mitsubishi
Toyo Kogyo
Toyo Kogyo
Toyo Kogyo
Toyo Kogyo
Toyo Kogyo
Toyo Kogyo
Toyota

Toyota

Toyota

Toyota

Toyota
Toyo t a
Family
08K4AA
08K4G
V304
V304
V345
V345


4-196
4-196

AITC
AITB
AITC
AITB
TL20C

TL20F

TL20C

TL20F

TL20C
T120F

TL20C

TL20F

G5T-C
G52T-F
G5T-C
G52T-F
C5T-C
G54T-F
G5T-C
G52T-F
CHAT
CHAT
CWBT
OWBT
CWBT
CHBT
2F(C>

2F(F>

2F(C)

2F(F)

JOR(TC)
20K(TF)
CID
400
400
304
304
345
345


196
196

111
111
111
111
119

119

119

119

119
119

119

119

121
121
156
156
156
156
156
156
120
120
140
140
140
140
258

258

258

258

134
134

Fed. or
Calif.
Calif.
Fed.
Calif.
Fed.
Calif.
Fed.


Calif.
Fed.

Calif.
Fed.
Calif.
Fed.
Calif.

Fed.

Calif.

Fed.

Calif.
Fed.

Calif.

Fed.

Calif.
Fed.
Calif.
Fed.
Calif.
Fed.
Calif.
Fed.
Calif.
Fed.
Calif.
Fed.
Calif.
Fed.
Calif.

Fed.

Calif.

Fed.

Calif.
Fed.
Additional
Technology in
California
Lower Catalyst
loading, Air Pump
Calibration,
Manual Transmission
Manual Transmis-
sion, More Inertia
Woight High Axle
Ratio, Calibration
Extra Speed Trans-
mission, Axle
Ratio, Calibration
Oxidation Catalyst,
Calibration
Oxidation Catalyst,

Greater Air,
Higher Catalyst
Volume and Loading

Greater Air,
Higher Catalyst
Volume and Loading

Greater Air,
Higher Catalyst
Volume and Loading
Greater Air,
Higher Catalyst
Volume and Loading

Pulse Air

Calibration

Calibration

Calibration

Extra Speed Trans-
mission, Calibration
Calibration

Calibration

Calibration



Calibration



Oxidation
Catalyst

4K
Certification
IIC
0.41
0.54
0.65
0.61
0.78
0.57


0.55
0.50

0.22
1.40
0.23
1.40
0.26

0.73

0.24

0.83

0.18
0.51

0.14

0.62

0.26
0.57
0.19
0.75
0.26
0.17
0.20
0.29
0.24
0.40
0.24
0.34
0.23
0.26
0.22

0.44

0.24

0.49

0.15
1.19
CO
5.18
12.74
4.98
4.72
6.80
5.52


8.90
6.80

4.29
14.00
2.73
12.00
2.97

9.00

2.16

12.00

2.61
6.50

2.61

9.50

3.83
7.64
2.49
7.17
3.54
3.42
3.16
4.20
2.37
6.23
2.50
7.56
2.57
6.72
3.40

8.73

3.10

9.49

1.89
13.82

Levels
NOx
1.50
1.30
1.36
1.75
a. oo
1.50


1.70
2.00

0.98
1.60
1.30
2.00
1.00

1.64

1.00

1.35

1.10
1.74

1.40

1.54

1.20
1.70
1.10
1.80
1.10
1.20
1.20
1.70
1.10
1.49
1.20
1.56
1.20
1.56
1.18
1
1.80

1.42

1.70

1.40
2.00


MPG
11.8
11.8
10.8
11.5
12.0
12.3


14.9
15.8

21.9
23.3
21.7
21.7
21.9

24. S

22.8

25.1

21.6
24.1

15.1

14.8

22.0
22.1
21.5
22.5
21.7
21.7
21.4
21.6
25.5
17.0
20.0
21.8
19.5
20.4
11.8

12.3

11.5

11.6

18.0
17.6

Percent
Difference
._

-6.1

-2.4



-5.7


-6.0

__


-10.6



-9.2


-10.4



+2.1


-0.5

-4.4

__

-0.9

-5.6

-8.3

-4.4


-4.1



-0.9


»2.3


-------
                    Table L-l (cont"d)

    Eii in ion and Fuel F.conony Data  for Light-Duty Trucks
Acquired From LPA's Emission Certification Tests  for  1980 MY

Vehicle
Model
Long Bed
Pickup
Long Bed
Short Bed
Pickup
Short Bed
Pickup
Bus
Bus

Camper
Camper

Truck
Truck
Truck
Truck
Truck
Truck



ENGINE
HFC
Toyota

Toyota
Toyota

Toyota

Vtf
VW

vw
vw

vw
vw
vw
vw
vw
vw
Family
20R(TC)

20R(TF)
20R(TC)

20R(TF)

11
11

12
12

37PC
37PF
37PC
37PF
37PC
37PF
CID
134

134
134

134

120
120

120
120

97
97
97
97
97
97

Fed . or
Cnlif.
Calif.

Fed.
Calif.

Fed.

Calif.
Fed.

Calif.
Fed.

Calif.
Fed. t
Calif.
Fed.
Calif.
Fed.
Atldit ional
Technology in
California
Oxidation
Catalyst

Manual Transmission,
Oxidation Catalyst,
Calibrat ion

3-Way Catalyst,
Closed Loop Carbu-
retor, Ho EGR
3-Way Catalyst,
Closed Loop Carbu-
retor, Ho EGR
Oxidation
Catalyst
Oxidation
Catalyst
Oxidation
Catalyst

4K


Certification Levels
HC
0.16

0.96
0.20

0.64

0.19
0.91

0.28
0.79

0.16
1.30
0.31
1.20
0.14
1.40
CO
1.89

12.83
2.19

9.87

3.80
13.00

7.60
10.00

2.00«
5.73
1.10
6.06
1.30
6.47
NOx
1.10

1.70
1.00

1.60

0.70
2.00

1.10
1.50
*
1.40
1.50
1.10
1.80
1.10
1.80
MFC
18.6

19.9
18.0

22.2

16.5
17.2

15.7
16.8

22.0
21.6
22.4
22.8
23.2
22.8

Percent
Difference

-6.5


-18.9


-4.1


-6.5


+1.9

' -1.8

+1.8


-------
     First  of all,  the  technology applied  in  California was  the
"add-on"  type  and  incorporated  no  technological  improvements.   The
California  strategies were  designed  to minimize  production  and
tooling  changes,  i.e., manufacturers  needed to  change the  large
volume  forty-nine  state  product to a "customized" product for  the
single  state  with  stricter emission  standards and not  unreasonably
chose  the easiest  method.   Fuel  economy  was  not as critical  a
design  parameter  as  the  economies  of  scale associated  with  the
production of similar vehicles.

     Secondly, as  presented  in  Table L-6,  the  fleet-wide  emission
reductions  required  for  California were significantly  greater  for
HC and  CO than those anticipated for 1983.  Less than half of  the
California HC  reduction and  12  percent  less of a CO reduction  are
required.   Only 5  percent more  of a NOx reduction will be needed,
and it can be reasonably argued  that  the 5  percent  is not  so much  a
reduction  in  emission  levels but  a reduction  in  emission  vari-
ability.*  Given the  fact that  less reductions  are necessitated by
the 1983 standards, it follows that the fuel economy impact will be
similarly reduced.   Experience tells us  that HC control follows CO
control  (i.e.  CO is  the more difficult of  the two to  control in  a
catalyst  system),  hence a 12 percent  less  CO reduction should, at
the least reduce the  fuel economy loss by  a similar amount,  i.e.,
from -4.51 to -3.97 percent  per  manufacturer.

     The  staff's analysis indicates  that in the worst  case,  i.e.,
where manufacturers  ignore   fuel economy considerations in engine
design,  and  introduce no  new technologies  of  the type already in
production  on  1981  passenger cars  utilizing  essentially the same
power  plants,  then  overall  engine  fuel economy will be reduced
approximately 4 percent per manufacturer.

     It  is  the staff's belief, however, that  this worst  case
scenario is  unlikely.   New emission  control technologies  (in
particular, electronic  engine controls) are  being marketed  today
which not only control  emissions  but  also enhance  fuel  economy.
*    No change in the statutory NOx standard has occurred,  however,
changes in the AQL  level  from 40 percent to  10 percent  imply  that
either lower low mileage emission targets or lower variability  will
be  required.   The  staff's  projected 1983  low mileage NOx  target
of  1.4 g/rai  is  conservative and assumes high  NOx  variability  on  a
test-to-test basis  during SEA audits.   This  assumption is  judged
extremely conservative on the basis of audit data from the  state of
California)._!_/  This data indicates  that  in 534 tests of GM, Ford,
IHC, and  Chrysler LDTs, after application  of  EPA's  estimated  full
life deterioration  factors, 9.4  percent  of  the vehicles  exceeded  a
NOx  level  of 2.35  g/mi;  if  a  particularly  variable Ford  engine
family  is discounted  (5.8M/6,6NA), then  in 441 tests only 4.3
percent exceeded the 2.35 g/mi  limit.   In short, the industry is
already meeting a 10 percent  AQL level  for NOx,  no  further  reduc-
tion in design  targets would be necessary, and therefore no  fuel
economy penalty associated with NOx control  is expected.

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     Electronic engine controls are  seeing,  widespread  use in
passenger  cars  in  1980,  and in  conjunction  with three-way cata-
lysts,  will see even more  use  in 1981  as  tighter NOx  and fuel
economy standards take effect.  Two systems used  today are General
Motors' C-4  (Computer Controlled  Catalystic  Converter)  system and
Ford's  EEC  III  system.  Both  systems  control  air/fuel  ratio  (for
use with  a three-way catalyst),  ignition spark timing,  air  injec-
tion, EGR  flow,  and  evaporative  canister purge.  In addition, the
C-4 system controls  idle speed and operation of the torque conver-
ter  clutch;  the EEC III also controls  throttle  kicker  position.
Each system  allows  highly  accurate optimization of the combustion
process over a  wide variety of engine  operating  modes  and  condi-
tions.

     Matrix  mappings of emission  generation  and  fuel consumption
are made  for every  possible  combination  of engine operating  condi-
tions .J/4/   Those  conditions  which  'are  either determined  by the
driver  ("for  design  purposes, the  "driver" is the Federal Certifi-
cation Test Cycle),  or which are  environmental  (engine temperature)
are then optimized for fuel economy and emissions  by generating the
optimum  combination  of  remaining engine  parameters  (e.g., spark
advance, EGR rate,  fuel/air  ratio,  etc.).  Over the full range of
operating  conditions,  these optimum  parameters take the form of
continuous mathematical  functions,  which  are  then  programmed
algorithmically into the control  unit  microprocessor.^/  The  result
is  an  engine whose  calibration continuously  varies in response to
driver and environmental demands, and which is  far superior  to the
static  mechanical   calibrations now present  on all  light-duty
trucks.

     It can be  argued that  engine  calibrations  significantly  affect
fuel economy and emissions,  as  illustrated  in Table L-2.   Several
Federal engine  families  were merely recalibrated to  meet the
California standards,  i.e.,  no hardware  differences exist.   Engine
recalibration can  lower the combustion  temperature  to reduce NOx
(spark  retard),  and  increase  the rejection of thermal   energy to
speed catalyst  light-off to  reduce  HC and CO; both effects  reduce
combustion  efficiency,  i.e.,  degrade  fuel  economy.   Electronic
controls can directly alleviate  fuel economy penalties while  also
controlling  emissions.   For  example,  continuously variable spark
timing  allows  cold  start  timing  such  that  catalyst  light-off is
enhanced, and to a much  greater degree  than a  single  static  timing
position would  allow.   Once catalyst  light-off  has  occurred (as
determined by a  temperature  sensor), the  control  unit switches the
timing  to  a  more fuel efficient  range.   In  short,  both HC  and CO
cold  start  emissions  are  controlled  and overall  fuel  economy is
enhanced.

     The magnitude  of the  fuel  economy  effect  is  dependent  pri-
marily  upon engine  size,  vehicle  inertia weight, and applied
emission control technology.   The National Highway Traffic  Safety
Administration  (NHTSA) in its preliminary analysis of  proposed  1983
fuel economy standards  for  light-duty  trucks2/  concluded  that  even

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                                 Table L-2

                  Fuel Economy Effects of Several  Emission
             Control Strategies in California Light-Duty  Trucks**
                  Number of Test
                   Data Points
                  on the Average
Additional
California
Technology*

3-way catalyst
  with feedback
  carburetors
Calibration only         8

Greater oxidation        8
  catalyst volume,
  loading, and
  additional AIR

Light-off catalysts      3
  alone
Light-off catalysts      9
  with all other
  changes

Overall average         38
  without light-off
  catalysts

Vehicle changes          5
  only
Vehicle changes         15
  with all other
  changes

Overall average         47
        Average
 Fuel  Economy Impact  (%)
..Calif,  mpg  - Fed, mpg
 	Fed, mpg

         -3.4
                                               -3.2

                                               -7.6
                                               -3.5

                                               -5.7



                                               -3.9



                                               -4.5

                                               -4.4



                                               -4.3
  Standard
  Deviation
of the Average

     3.6
                                  2.7

                                  5.8
                                  4.9

                                  9.3



                                  5.5



                                  4.5

                                  9.07



                                  6.3
*     NOTE:   Where no differences in emission  control hardware  are
indicated between California  and  Federal  vehicles  (as  evaluated
from  EPA Certification  records),  and  significant  emission  level
differences exist, this  analysis assumes that  a  change  in calibra-
tion  (spark  timing,  distributor curve,  carburetor  setting)  has
occurred.   It is understood that calibration  changes  can and  may
have  occurred during the application of  any other technology.

**    This table  makes  no correction for 8-cylinder engine/higher
inertia weight vehicles, (see Table  L-3).

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                                 Table L-3
             Projected Fuel Economy Impact of 1983 Regulations
          (Using Current Engine Mix and No Technology Improvement)
Comparative
(Fed. /Calif.)
Families
(# cylinders)
Fuel
Economy*
Impact (%)
Projected
Sales
Fraction**
Sales
Weighted
F.E. Impact
AMC BT9A1/BT6C1            (4)
AMC CT3A1/CT4W1            (6)
AMC CT3H1/CT4W1            (6)
AMC HT3A1/HT2V1            (8)***
AMC NT3A1/NT3A1            (8)***
Chrysler 225 BCP/BXP       (6)
Chrysler 318/360 BFP/BCP   (8)***
Ford 4.9 NA/ND             (6)
Ford 5.0 NA/NB,NG          (8)***
GM 08K4G/08K4AA            (8)***
Nissan TL20F/TL20C         (4)

Mitsubishi G527F/G57C      (4)
Toyo Kogyo OMAT/OMAT       (4)
Toyo Kogyo OWBT/OWBT       (4)
Toyota 2F(F)/2F(C)         (6)
Toyota 20R TF/TC           (4)
VW 37PF/37PC               (4)
IHC V304/V304              (8)***
IHC V345/V345              (8)***
IHC 4-196/4-196            (4)
Isuzu AITAB/AITC           (4)
      + .5
   -3.2,-8.5
     + 3.2
  -14.8,-11.6
    -4.0,-4.0
      + 11
-4.0,-4.0,-11.5
   +3.«7,-10.6
-3.1,-2.0,-5.6
   -8.2,-19.5
      -15.6
      -4.0
+2.1,-10.4,-9.2
      -10.6
-.5,-4.4,0,-.9
      -5.6
   -8.3,-4.4
   -.9,-4.1
+2.3,-6.9,-18.9
+1.9,-1.8,+1.8
      -6.1
      -4.0
      -5.7
     -6.0,0
                                          Totals =
      Adjusted totals  for  sales not represented  =
 .0093
 .0241
 .0142
 .0060
 .0252
 .0257
 .0391
 .0787
 .1341
 .2277
 .0249

 .0099
 .0105
 .0081
 .0026
 .0197
 .0026
 .0047
 .0053
 .0016
 .0178

 .6918
1.0000
+.0046
-.1410
+.0184
-.0792
-.1008
+.2825
-.2542
-.5430
-1.2717
-.9108
-.1749

-.0144
-.0589
-.0529
-.0066
-.1520
+.0016
-.0287
-.0112
-.0091
-.0534

-3.57
-5.15%
*    From Table L-l.
**   EPA certification records - manufacturer's projected sales for
1980.
***   It is  assumed  here that some  8-cylinder  engines  are used in
vehicles whose  inertia weight  is  high enough to result in certifi-
cation  to California  standards comparably stringent to 1980 Federal
standards (i.e.,  fuel economy comparisons are not indicative of the
effects  of  the  1983 Federal  standards).    To  compensate,  a  fuel
economy penalty of 4  percent is assumed  for all vehicles exhibiting
less of a penalty.    This  4 percent  is based upon comments attrib-
uting  a  4  percent  loss on 8-cylinder engines due to  air  pump
addition.

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                                 Table L-4

                        Impact of 1983 Regulations,
                     Using Projected Fleet Engine Mix
                   (Assuming No Technology Improvements)
Adjusted Sales Fractions*
4 cylinder
6 cylinder
8 cylinder
Totals
1980***
.151
.210
.639
.999*
1983
.15
.40
.45
1.00
Adjusted Fuel Economy Penalty
1980***
-.736
-.563
-3.85
-5.15
1983
-.731
-1.072
-2.711
-4.51
*     Some  totals  do not add  up to 1.000 due  to  round-off  error.

**    For 1983  sales  projections,  see Chapter  5 of  the  Regulatory
Analysis of this rulemaking.

***  From Table L-3.

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                                                  Table L-5

                             Sales Weighted (by Current Federal Sales) Emission
                          Contributions of 1980 Federal and California LOT Fleets
     Comparative
Families (Fed./Calif.)

AMC BT9A1/BT6C1
AMC CT3A1/CT4W1
AMC CT3H1/CT4W1
AMC HT3A1/HT3V1
AMC NT3A1/NT3A1
Chrysler 225 BCP/BXP
Chrysler 318/360 BFP/BCP
Ford 4.9 NA/ND
Ford 5.0 NA/NB,NG
GM 08K4G/08K4AA
Nissan TL20F/TL20C
Mitsubishi G52TF/G5TC
Toyo Kogyo OMAT/OMAT
Toyo Kogyo OWBT/OWBT
Toyota 2F(F)/2F(C)
Toyota 20R TF/TC
VW 37PF/37PC
IHC V304/V304
IHC V345/V345
IHC 4-196/4-196
Isuzu AITB/AITC
                                    4K Emissions (Fed./Calif.)
       Sales-Weighted 4K
    Emissions (Fed./Calif.)
HC
.42/.18
.42/.S6
.67/.40
.84/.33
.64/.37
.S8/.23
.55/.30
.72/.24
.60/.35
.54/.41
.67/.21
.4S/.23
.40/.24
.30/.24
.47/.23
.93/.17
1.30/.20
.61/.65
.S7/.78
.50/.55
1.40/.23
CO
5.62/2.47
9.52/5.64
6.35/4.43
7.07/3.35
13.00/9.50
11.00/1.81
10.35/7.90
6.90/4.15
6.89/3.53
12.74/5.18
9.25/2.59
5.61/3.26
6.23/2.37
7.14/2.54
9.11/3.25
12.18/1.99
6.09/1.47
4.72/4.98
5.52/6.80
6.80/8.90
13.00/3.51
NOx
1.50/1.30
1.70/1.25
2.00/1.41
1.65/1.19
1.51/1.84
1.60/1.28
1.18/1.45
1.46/1.75
1.58/1.58
1.30/1.50
1.57/1.13
1.60/1.15
1.49/1.10
1.56/1.20
1.75/1.30
1.77/1.17
1.70/1.20
1.75/1.36
1.50/2.00
2.00/1.70
1.80/1.14
                                                             Total =

                                                  Adjusted Totals* =
                                                                 Federal:
                                                              California:

                                                    1983 Federal Targets:
HC
.0039/.0017
.0101/.0087
.0095/.0057
.0050/.0020
.0161/.0144
.0149/.0059
.0215/.0117
.0567/.0189
.0805/.0469
.1230/.0934
.0167/.0052
.0045/.0023
.0042/.0025
.0024/.0019
.0012/.0006
.0183/.0033
.0034/.0005
.0029/.0031
.0030/.0041
.0008/.0009
.0249/.0041
.423S/.2378
.61
.34
CO
.0523/.0230
.2294/.1359
.0902/.0629
.0424/.0201
.3276/.2394
.2827/.0465
.4047/.3089
.5430/.3266
.9239/.4734
2.9010/1.180
.2302/.0645
.0555/.0323
.0654/.0249
.0578/.0206
.0237/.0085
.2399/.0392
.0158/.0038
.0222/.0234
.0293/.0360
.0109/.0142
.2314/.0625
6.779/3.1466
9.80
4.55
NOx
.0140/.0121
.0410/.0301
.0284/.0162
.0099/.0071
.0381/.0464
.0411/.0329
.0461/.0567
.1149/.1377
.2119/.2119
.2960/.3416
.0391/.0281
.0158/.0114
.0156/.0116
.0126/.0097
•0046/.0034
.0349/.0230
.0044/.0031
.0082/.0064
.0080/.0106
.0032/.0027
.0320/.0203
1.0198/1.0230
1.47
1.48
.49
5.50
1.40
     Adjusted for sales not represented.

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                                                   Table L-6
                                1980 California and Federal  4K Emission Levels
                                Sales-Weighted at  1983 Engine Mix  (Fed. /Calif .)
4
6
8


%
1980*
HC CO NOx
cyl. .1143/.0324 1.3867/.4120 .2480/.1764
cyl. .1336/.0575 1.6898/.8390 .33257. 3184
cyl. .36437.2538 6.7232/.3.326 .8936/.9850
1983 Federal Estimated Targets:
% Reduction from 1980 Federal to 1980 California:
Reduction from 1980 Federal necessary for 1983 Federal:
1983*
HC CO NOx
.1135/.0322 1.3775/.4093 .2464/.1752
.2545/.1095 3.2187/1.5981 .6333/.6065
.2565/.1878 4.7346/2.3423 .6293/.6930
.49 5.5 1.4
HC CO NOx
-48% -53% -2.6%
-21% -41% -7.3%
*    From Table L-5.
*'*•   Using adjusted sales fractions from Table L-4.

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with a  hypothetical  5 percent engine  fuel  economy penalty due  to
emission control in 1983, an overall increase in fleet  fuel  economy
will occur due  to  vehicle improvements.   Furthermore,  it has  been
demonstrated that shifts in consumer buying  habits  toward more  fuel
efficient product lines  in California have  made the  1980 LOT
California fleet more fuel efficient than the 1980  Federal  fleet  by
6.5 percent !J/8_/  Shifts in market share  do  not  directly offset the
effects attributable to tighter emission  standards, however, and  it
is viewing the  engine as  <*  separate  entity  with  which  the  analysis
will be primarily concerned.

     NHTSA stated  that  it  believed  a 3 percent  average fleet  fuel
economy  improvement  to  be a  reasonable  estimate of the effect'  of
electronic engine  controls,  presuming  introduction of  a variety  of
controls of varying levels of sophistication in  1982.j>/ NHTSA  also
quoted  a range  of 3-5 percent  improvement which they  believed
attributable  to electronic  engine   controls.^/    The  EPA  Staff's
analysis of  electronic  engine  controls  - in particular their
availability and fuel economy potential - is presented  in Reference
7.  Based upon a review of the published  literature, the Staff must
conclude that electronic engine controls  of  moderate complexity (in
particular  electronic  spark  advance  and EGR modulation)  will  be
sufficient to offset  the worst case 4 percent  fuel economy impact
of the  1983  emission standards on the average engine.  (Note  that
there are  HC and  CO  control  strategies  which do  not  degrade  full
economy, e.g., increasing oxidation  catalyst volume and noble metal
loading.   In conjunction with  electronic  spark advance to handle
transient warm-up/catalyst light-off conditions,  the 1983 HC and  CO
standards will  not be difficult  to  attain.)  The  EPA staff, how-
ever, takes  issue with  NHTSA's  claim that  the  use of EEC's will
become  prevalent in  1982.   This  claim  is  too optimistic.   The  only
electronic controls used  in  1981  LDT's are  a few California engine
families (AMC, Ford), and to presume a 100 percent  fleet conversion
to EECs  the  very next model year (1982) is  unreasonable.   The EPA
staff foresees a phased introduction of EECs into the Federal  fleet
beginning  in 1982  and  reaching  universal  incorporation  by  1985.
The  motivating   force  for  this  introduction will   be  the  need  to
maintain  fuel economy with  decreasing  emission  standards.   This  is
the  basis  for  EPA's  position that  no net  fuel economy impact  is
attributable to  the  1983 LDT standards,  because  moderately complex
EECs  will be  incorporated at  that time  to allow simultaneous
compliance with both emission and fuel  economy standards.   In
short, no degradation in fuel economy is  anticipated.

     The  staff   also  concludes  that the  exact   control strategies
used for  1983 will depend upon  the  fuel  economy standards  mandated
by NHTSA.   In the absence of  a  sizeable NOx reduction, the use  of
three-way catalysts  and  feedback carburetors is  not necessary  from
an emissions  standpoint.   Compared  to an engine with  conventional
EGR, however, a  three-way system  is more  fuel efficient.   With the
statutory  NOx  reductions scheduled  for  1985,  the staff  believes
that three-way catalysts, feedback carburetors,  and full electronic
controls  will   be  universally used  in  1985 and  later light-duty

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 trucks.  These will be basically the same  systems which are already
 used on the 1981 passenger car fleet.   Recognizing the fuel economy
 benefits of the three-way system,  it is reasonable to conclude that
 this  technology  — available  today  on a mass  production  basis  -
 could,  but most  probably  will not,  be  applied  in 1983.   On  a
 fleetwide basis,  electronic  controls with  infinitely variable
 calibration potential  for spark timing and  EGR modulation should
 alleviate  any  potential  fuel  economy penalty  without the need for
 three-way  systems,  although  that option  does  exist.   These elec-
 tronic  controls  need not  be as complex as  the  more elaborate
 systems  (e.g.,  General  Motors'  C-4)  and hence  need not be  as
 expensive to manufacture.

     In  summary,  the staff  considers that   the  worst possible
 scenario for 1983 light-duty truck fuel economy involves absolutely
 no  technological innovation.  This "quick-fix" approach - with due
 regard to the relative stringency of the  1983  standards - would at
 most result in an engine  fuel  economy penalty of 4.0 percent.  Even
 for  this  case, a  net increase  in  fleet  fuel  economy  is  antici-
 pated.  However, tried and  proven new  control  technologies are on
 the  market today  which  can alleviate any engine fuel  economy
 penalty  attributable  to  the  emission  standards.    More  advanced
 technology - anticipated  for 1985 at  the latest  - can increase fuel
 economy over and above the 1982 level.   The staff believes that the
majority of manufacturers will  incorporate controls consistent with
 today's technologies  (e.g.,  oxidation  catalysts, EGR,  air injec-
 tion) in addition  to  electronic controls  for  spark timing  and EGR
modulation to  maximize  performance  and fuel economy.   Some manu-
 facturers  (Volkswagen, for  example)  may elect  to introduce three-
way  catalyst/feedback carburetor  systems  in 1983  to enhance  fuel
 economy.    In  conjunction  with NHTSA's future  fuel  economy stan-
 dards, the 1983 fleet  will be more fuel-efficient than today's.  As
 discussed  above,  technological modifications   to achieve  the  1983
 emission standards  need  not degrade the  fleet  fuel  efficiency  of
 light-duty truck engines.

     4.    Recommendation

     No net  fuel  economy penalty is attributable  to the proposed
 light-duty truck  emission  standards within  the  range  of  cost
 effective technological options open  to the industry.

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                            References

_!/   "Analysis of  California  2%  Audit Data," by T.  Tesoriero,
     March,  1980,  available  in the Public Docket No. OMSAPC-79-2.

2/   "Preliminary  Regulatory  Analysis  of  Light-Duty  Truck  Fuel
     Economy  Standards,  Model Year  1982-85,",  National  Highway
     Traffic Safety Administration, December,  1979.

_3/   "Optimization of Automotive Engine  Calibration  for  Better Fuel
     Economy - Methods  and Applications," U.E.  Auiler, et al., SAE
     Paper 770076.

tjj   "Spark  Ignition Engine  Fuel  Economy  Control  Optimization -
     Technique  and Procedure,"  T.  Trella,  SAE  Paper  790179.

5/   "An Approach  to a Standard Engine Management System for 1983
~~    and Beyond," by R. Matney, et al.,  SAE Paper 800470, February,
     1980.

6J   "Light  Truck Average Fuel  Economy Standards:    Standards for
     1982 Model Year,"  45 FR 20874, March 31,  1980.

7/   "Electronic  Engine Controls  -  Availability, Durability, and
~    Fuel  Economy Effects on  1983 and  Later  Model Year  Light-Duty
     Trucks,"  by T. Cox, Z.  Diatchun,  T.  Nugent, Draft EPA  Tech-
     nical Report,  June 1980.

8/   "Passenger  Car and  Light Truck Fuel  Economy Trends Through
~~    1980,"  by  J.D.   Murrell, et.al.,  SAE  Paper NO.  800853.

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M.    Issue:  Environmental Impact

      1.   Summary of the Issue

      In  the  draft  Regulatory Analysis which accompanied the NPRM,
EPA had,  among other things, examined the environmental impact of
the proposed  regulations,  the cost effectiveness of the proposal,
and possible  alternative  actions.   One reason for preparing these
analyses  was  to  satisfy the  requirements of Executive Order 12044,
Improving  Government Regulations.   A  number  of  comments  on the
accuracy and completeness  of the Regulatory Analysis materials were
received during the comment period.

      2.   Summary of the Comments

      Commenters identified what they felt were  two missing elements
in  the  analysis  of the NPRM.   These missing  elements  were in the
cost  effectiveness analysis  and  the  requirement  for preparation of
pollutant specific studies.

     Although  EPA had  evaluated  the overall benefits  and  cost
effectiveness of  the rulemaking,  comments  were directed at a lack
of analysis of individual  components of the proposal.   Such analy-
ses,  commenters believed,  were required by  Section 317 of the Clean
Air Act and by Executive Order  12044.   Included  in the  analysis of
individual components  (i.e., emission standards, diesel crankcase
control,  revised  definition of  useful  life,  revised  durability
provisions,  revised  maintenance  provisions,  SEA, PCA)  should  be a
consideration of alternatives to those components.

     Cummins  engine  company  commented on  EPA's  failure to follow
what it considered to be the  standard setting framework  of the 1977
Clean Air Act amendments for  those  light-duty  trucks in the 6,000-
8,500 Ib. GVW range.   Cummins  interpretation of this  standard
setting framework  is presented  in  Figure M-l.    In that framework,
the Administrator  has  two paths  to follow in establishing target
standards.  The first is via the percent reduction requirements of
Section 202(a)(3)(A)(ii).   This section establishes the  requirement
for a 90 percent reduction in HC and  CO for 1983, and a 75 percent
reduction in NOx  for 1985.  The second path is  via the "pollutant
specific studies"  of Section 202(a)(3) (E).  On the basis  of these
studies,  the Act  allows   the  Administrator  to change the  above
percent reduction standards for Section 202(a).

     Once the target standards  were  established, the Administrator
has the further  option  of  a  temporary revision  to those standards
based upon considerations  of  technology, cost and fuel penalty.  If
made,  such  a revision would  be effective for a 3-year  period,
beginning 4 years after adoption.

     Cummins   indicated  that  in  its  interpretation,  this  entire
process was  to  have  been  completed by  December 31, 1978,  for
standards effective in 1983.   Every  3  years after that  the process
                                1*41

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                     FIGURE M-1


                   CLEAN AIR ACT


             202(a)(3)(A),  (B), and  (E)

                As Interpreted By Cummins
             ->—Health  Effects  Study
                          or
Target Standards

based on 90%,  75%
reductions  from
uncontrolled  levels
                 \
                 Temporary Revised
                 	Standards

                 based on available
                 technology, energy
                 and cost penalties
   Target Standards

   based on health
  •effect requirements
effective 4 years after
adoption
  every 3 years

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would  be repeated,  with  an opportunity  to  change  or  vevise the
standards once  again.   Cummins  felt that,  rather than  simply
relying on the statutory percentage reduction  requirements, EPA was
to  conduct  its  standard  setting  while cognizant of  the  basic
underlying purpose of  the  Clean Air  Act  to  "promote  the  public
health and welfare."

    EPA  received  a number  of  specific comments (principally from
Ford)  on  the methodology used  to conduct its  environmental analy-
sis.   Ford cited  what it found to  be  incorrect treatment of  Cali-
fornia regions (which, of course, are  subject  to a distinct set of
emission standards).   Ford stated  that "(t)he  calculated air
quality gains associated with this  incorrect assumption are greater
than the  benefits  associated with  the  proposed  regulations."  Ford
also felt that the EPA analysis  supported  the  position that most of
the air quality gains expected in future years  would occur whether
or not the NPRM were  finalized.  Ford  stated  that  redefined useful
life and  in-use vehicle durability  testing were not proven to have
a significant air  quality  impact.   Ford indicated  its belief that
the benefits  were so small  as to  be unnoticeable.

     Ford went on  to prepare air  quality projections  of its own,
using  the EPA MOBILE 1 and  rollback models.   The  details of that
analysis can  be found in  the Ford   submission of October  11,  1979,
beginning at  page  4 of Section VI.   The results  supported Ford's
position  that  the  light-duty truck NPRM,  as  a whole,  would have
little air quality benefit  compared to  the air quality improvements
already projected due to other source  reductions,   and that redefi-
nition of useful  life  also  has  little or no  associated benefit.
Ford's analysis also indicated  that  a very moderate I/M program (10
percent  stringency and no mechanics  training)  would  provide a
greater air quality benefit than  those  achieved by  the proposed LDT
standards in  1983.

     In its  air  quality analysis,  Ford also  examined the proposed
idle standards.    Because  of the  regional  nature   of  oxidant air
pollution, Ford felt  there was no  basis  for  an HC idle  standard.
Relative  to  CO,  Ford attempted to  assess the effect of  that pro-
posed  standard  by  applying speed  correction  factors to the EPA
emission  factors.   These  showed  that the  rollback model  would
predict a  greater  improvement  in  air  quality for  areas  characte-
rized by  lower average  traffic speeds  than for  areas characterized
by higher average  traffic  speeds.   Ford drew the  implication that
this "suggests that the idle mode  for CO may not be as important as
EPA seems to  have  implied ..."

     Ford indicated  that when  the exhaust  HC  emission  rates are
broken  down   into  methane   and  non-methane  fractions,  methane  is
shown  to  be  a significant  portion of the  total.  This methane
fraction, Ford believes,  should  be excluded  from  exhaust measure-
ments because it  is photochemically inert.

     Comment   from  GM and  others pointed out  that  tamper-resistant

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components would  be  appearing on  light-duty trucks.   EPA'«= para-
meter adjustment regulations take effect in 1981 and 1982, and the
impact of these regulations  on in-use vehicle emissions needs to be
accounted for in the  analysis  of  benefits.

     The  Alaska  Department  of Environmental Conservation  and  the
EPA Alaska Air Coordinator drew attention to the fact that emission
rates for  CO are known to  be  highly  temperature  dependent.   They
therefore felt  that  the  projected  emissions  and air quality bene-
fits for CO would not be  fully realized  in Alaskan regions.

     3.    Analysis of the Comments

     The  EPA staff  shares  the  desire of commenters for  a more
detailed cost effectiveness  analysis of the  components  of  the
rulemaking.   However, as was noted in the  preamble to  the  NPRM
(44FR 40793,  July  12,  1979),  there was  a lack  of data on which to
base such analysis.  During the  comment period, EPA has endeavored
to  collect  sufficient information  to  examine   costs  and  benefits
associated with  the  several elements of the  rulemaking.   Although
many of  the  difficulties  facing  the technical staff at the time of
the  NPRM are  still  present,   an analysis  of the elements  of  the
final rulemaking has been prepared and can be found in Chapter VII
of the Regulatory Analysis.

     The  Cummins  interpretation  of the 1977 Clean  Air  Act amend-
ments regulatory  scheme is  not a new one  to  the EPA technical
staff.  This issue was also  raised  during the rulemaking action for
1984  and later heavy-duty  engines.^/   Concerning  the  "pollutant
specific studies" required under  Section 202  (a) (3) (E), it is the
technical staff's  opinion that,  although  not specifically identi-
fied  by  that  name,  these  studies  have in fact been  completed  -
first as part  of  the draft  Regulatory Analysis,  and now  in  the
final Regulatory Analysis.  The Regulatory Analysis takes a compre-
hensive   look at  the  environmental  impact  (i.e.  health and welfare
effects  via  the  ambient air  quality  standards)  of the  control
strategy  represented  by  the  statutory  90  percent  reductions.   It
also  considers alternate  standards  of varying stringency,  along
with such aspects as  costs and cost effectiveness.

     The EPA technical  staff  does not  subscribe to  the  dual  path
options   as  described by  Cummins.    In  reality, if  that  approach
were followed, the Congressionally  prescribed percentage reduction
targets  would have no meaning  and might never be used.  It is most
unlikely that the pollutant  specific study would identify precisely
the  same percentage  reductions  contained  in the  Amendments.
Rather,   the  process  is   a  sequential  one,  wherein  the  pollutant
specific  study  is  used to  evaluate the level  or  control desired
by Congress from an environmental health viewpoint to determine its
appropriateness.  The  study  would consider  the  effects  of  the
statutory percentage reductions, and  if these  were desireable and
adequate in the context of  emission  reduction  and air  quality
benefits,  then those percentage  reductions would be retained.

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 The  Administrator could also decide to change the  standard. Making
 this judgment would  include  consideration of  such things  as
 the  gain or loss of benefits associated with more  stringent or less
 stringent standards.

     We do not  view the  pollutant  specific  studies as intended  by
 Congress  to double check  the  standard which  it chose,  or  as a
 condition  precedent to  promulgating  standards  at  the  statutory
 levels.   If  that were the  case, we would  expect  Congress  to have
 first  applied  the concept  to  light-duty  vehicles, not heavy-duty
 trucks.   It  is  there that the greatest  environmental and economic
 impacts of a  given  standard occur.   Rather,  the statutory percen-
 tage  reductions serve as a  starting  point  which  represents  the
 desire of Congress.   The  pollutant  specific studies provide a means
 of changing those standards  in  the  case  of a significant environ-
mental need  to do  so. This is consistent with the  Clean  Air Act
 provisions for  the  use of the pollutant  specific  study,  which is,
 in the wording  of Section 202 (a)  (3)  (E) (ii), for "changing any
 standard  prescribed...."  according to  the  statutory reductions.

     The technical  staff  acknowledges that Congress had originally
 envisioned the above process as  taking place in 1978,  for standards
 applicable in the 1983 model year.   For further discussion of this
matter see "Issue E  - Leadtime."

     We will  now turn to  the comments  on EPA's environmental
 assessment methodology.   The technical  staff  agrees with  the
 comments concerning  analysis  of California regions.   Since Cali-
 fornia maintains its  own  emission  standards,  the  staff recommends
 analyzing only non-California regions in the  final Regulatory
Analysis.

     The  technical  staff  also  agrees with  those  commenters  who
 pointed out  that most  of the  overall  air quality improvements
 projected  for  future  years  would occur  whether or  not  new light-
duty truck regulations  are adopted.  However,  the staff strongly
disagrees  with  the  conclusion  of  commenters  that  the light-duty
 truck  regulations are  therefore unnecessary,  or   of  minor value.
For indeed, the overall air  quality improvements can be broken down
 into any  number of  smaller increments  related to various source
categories -  such  as light-duty vehicles, heavy-duty trucks,  and
various stationary source categories.   The fact that each of these
categories produces  incremental benefits which look small compared
to the  sum total cannot  be used to  dismiss  the  import of those
categories, or  the  total benefit would  soon  be gone.   The total
array  of  air  quality improvements resulting from other known
control strategies  here  forms a backdrop or  environment  in whichi
the  light-duty truck regulations  play a  role commensurate  with
their relative emission rates.

     Ford   claimed  that  its air quality  analysis  indicated  that
redefined  useful life and in-use durability  testing had  no proven
benefit.    That  analysis  was based upon  Ford's  interpretation and
extension  of work in the draft Regulatory Analysis.  Ford used the

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"worst case" assumptions  about  in-use  deterioration  in  its  assess-
ment.   These  worst  case  assumptions  minimize  the  effects of
extended useful  life and  over-state  the  relative importance of  I/M
programs.    In  preparing  the  final  Regulatory Analysis, the  tech-
nical staff has  found that the worst case assumptions from the draft
analysis were  unnecessarily pessimistic, and has developed a more
realistic approach.    The final  Regulatory Analysis  also  will
analyze the  benefits  of  individual  components  of  the package  and
evaluate their cost effectiveness.

     Concerning  the  need for  idle  standards, the technical  staff
has recommended  elsewhere (Issue D - Idle  Test and Standards) that
the HC idle standard be deleted from the  final rule.   The staff has
further recommended retention of the CO idle standard.   The  ration-
ale  for that  decision  is  set  forth  in  the above  issue  analy-
sis.   The argument here advanced by  Ford using speed  correction
factors to  the mobile  source emission  factors is tenuous at  best.
Ford  itself  hesitates  to draw  anything  more than   a "suggestion"
from  it.   The speed correction factors  are not valid means of
estimating idle  emissions.   They apply to grams per  mile emission
rates, which clearly do  not fit the  idle case where  the  vehicle is
emitting while standing still.

     In  agreement with  the  suggestion  by Ford, the air  quality
analysis  will  be  done  on  the  basis  of  non-methane fractions  of
hydrocarbon  emissions.   This change makes the mobile source  emis-
sion  factors  consistent with the non-methane  hydrocarbon emission
rates used  for stationary source categories  in  the emission inven-
tors  data base.  Cost  effectiveness  calculations,  on  the  other
hand, have  historically  been  based  on total hydrocarbons.    Since
total hydrocarbons are  being  reduced by  the regulations, and  since
a prime function of cost effectiveness is  to  provide a  measure  for
comparison with  other  strategies,  total  hydrocarbons will continue
to be used for cost effectiveness.

     The  GM  comments  concerning the need  to  consider the pre-1983
impact  of parameter adjustment regulations  for light-duty trucks
are well taken.   The final  Regulatory Analysis will  include  correc-
tions to  the emission  factors  to incorporate the effect of param-
eter adjustment.

     Comments  concerning CO problems  in Alaskan regions were also
valid.   The emission factors  used  for the air  quality  assessment
are  not appropriate for areas of persistent low  temperatures.
Therefore, Alaskan regions, along with California and high-altitude
regions,  will  be excluded  from the  air  quality assessment.  This
does not  imply a lack  of benefit in Alaskan or high-altitude  areas
from this rulemaking.   If,  for  example, manufacturers had to reduce
cold-start emissions in order to meet  their target emission  levels,
then  Alaska  might experience a substantially  greater benefit than
predicted.   The  staff  does not believe  that this rulemaking need
include provisions  or   analysis  for  non-FTP  test conditions  since
this  problem  is being  looked  at  elsewhere.   Further  discussion

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can be found in Issue N:  Special Exemptions.

     4.   Recommendations

     The staff recommends that the following changes  be  included  in
the final Regulatory Analysis.

     1.   Expand the  cost  effectiveness  analysis to  include  anal-
ysis of individual elements of the rulemaking.

     2.   Exclude  California,  Alaska,  and  high-altitude  regions
from the air quality assessment.

     3.   Consider non-methane  hydrocarbon  emissions  in  pre-
paring the air quality impact analysis.

     4.   Incorporate  the   effect  of  light-duty  truck  parameter
adjustment regulations  into  the  1981  and 1982 model  year  emission
factors.

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                      References

For discussion see  "Summary  and  Analysis  of  Comments  to the
NPRM:   1983 and Later Model Year  Heavy-Duty Engines, Proposed
Gaseous  Emission  Regulations,"  December  1979,  p.  268.

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N.   Issue:  Special Exemptions

     1.   Summary of the Issue

     EPA has received comments in two areas  that  do  not  fall within
the  boundaries of major  issue  categories covered  in  this document.
Both  deal  with  special  situations  which   the  commenters  believe
require special  treatment.  These issues  will be analyzed as
Special Exemptions.

     2.   Summary of the Comments

     a.   Exemption From All  Emission Regulations  of Trucks up to
          9000 Pounds Licensed as Agriculture  Vehicles

     The New Mexico Cattle Grower's Association  (NMCGA)  has requested an
exemption from  the new  rulemaking  and a modification  of existing
regulations  for  trucks  up  to 9,000  pounds that are  licensed as
agricultural vehicles.   The  following  issues  represent  the Associ-
ation's major justifications for  exemption:

     (1)  Insignificant environmental  degradation due to  vast
emission dispersion.

     (2)  Increased vehicle cost.

     (3)  Increased vehicle fuel  consumption.

     (4)  Decreased vehicle reliability.

     (5)  Decreased vehicle power output.

     (6)  Catalytic Converters.

          (a)  Dual  bulk storage  requirement to  handle unleaded
               fuel.
          (b)  Increased demand on unleaded  fuel  supplies.
          (c)  Conversion of other farm vehicles  to  unleaded fuel.
          (d)  Range fire potential.

     (7)  Electronic  ignition problems of unreliability and unre-
pairability.

     (8)  Additional  costs  associated with these regulations will
be borne by the consumer.
                                                                  t
     b.    Low Temperature CO Emission Problem and Applicability of
          the Federal Test  Procedure (FTP)  to Areas  With Typically
          Lower Operating Temperatures

     The Alaska Department  of Environmental  Conservation (ADEC) and
the Municipality  of Anchorage  have  indicated concern over the
proposed control measures  and applicability  of  the FTP for areas

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that  typically  experience  low-temperature  winters.   ADEC  specif-
ically  addresses  the need  for certification or deterioration
rate  testing  to  be conducted over  a  full  range of  temperatures.
Since  Alaska's  nonattainment  problems  are  primarily  related
to  cold  starts,  the  Department  indicates  that if low  cold-start
test temperatures are not instituted,  the added vehicular cost  for
emission control  will  not result in  the stated 26 percent reduction
of  CO  in Alaska or  in  other states  experiencing wintertime CO
problems.

     Input  from the  EPA Air and  Hazardous Waste  Division and
its  Alaska  Air  Coordinator  is  in  agreement indicating that  the
proposed regulations do  not  control cold temperature CO emissions
or  reduce CO emission  by  the aforementioned  figure  and  should
therefore be revised to control  CO emissions  at temperatures  below
75° F.

     3.   Analysis  of Comments

     a.    EPA's analysis  of  the  NMCGA comments has  indicated
that  direct  application  to non-agricultural  vehicles can be made
for  a  majority of  the  issues.   EPA  therefore, does not consider
them  adequate  justification  for  regulatory exemption of the  vehi-
cles  in  question (light-duty trucks).   Two concerns, however,  the
potential of  catalyst ignited range fires  and  the  requirement  for
dual  bulk  fuel  storage capability, are directly related  and
deserve analysis.

     Studies conducted principally by the U.S.  Forest Service have
indicated that catalyst  equipped vehicles exhibit no significantly
higher fire potential than pre-catalyst vehicles.   This  is  because
catalyst  skin temperatures  are  similar to  pre-catalyst  exhaust
system  temperatures.    These  simple  statements  are  not meant  to
evade  the  issue.   EPA  realizes  the  potential  for  some increased
hazard  in range or range  like  situations  but we  believe that
control of  the problem  is  the  responsibility of the manufacturer.
The failure or destruction rate of  this  equipment is an additional
problem  to  be solved via the design  route not through  regulation
revision.

     Concerning  the  need to acquire  bulk storage  capability  for
storing unleaded fuel,  it  is important  to  note that  catalysts  are
already  in  use on  virtually all  light-duty  trucks as  a result of
existing regulations.  Finalization of this  rulemaking, therefore,
will  have no  significant  impact on that situation.   Since  the
number of agricultural vehicles.in this category is increasing each
year it would  appear reasonable to  assume  that a dual bulk storage
capability is  being acquired  on  an ever  increasing number  of
ranches.   Furthermore,  the high  potential that ranchers'  private
automobiles utilize unleaded fuel  would serve as added incentive to
acquire that  capacity.   It is also a logical  assumption  that  the
ever  increasing demand  for  unleaded fuel will  result  in a  propor-
tional supply increase.

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     Other  concerns,  if  these  vehicles  were  exempt,  include
 possible vehicle resale  for full-time on road  use.  Emission
 control  at  that  point  would be  nonexistent  and it  is  unreason-
 able to assume, due to time and  dollar  costs involved, that control
 devices would be installed prior to  resale.  In addition, a produc-
 tion  run to produce exempt  vehicles would result in  increased
 "special production" costs that  may negate  potential  savings
 arrived  at  by catalyst or  other  emission  control  device elimina-
 tion.

     b.   EPA  recognizes"the low temperature  emission  problem and
 that of applicability of  the FTP  to  Alaska and further acknowledges
 existence of these problems in other areas of the country as well.
 The Agency  is  currently  in the  process  of  developing  a  cold room
 for the simulation  of low temperature test conditions  (20°F).
 Testing,  to be  conducted,  will provide data  required  for  the
 development  of FTP guidelines  for  low temperatures.

     The strategy for low temperature emission control  assumes the
 use of  electronic engine control systems.  These  systems  provide
 the potential  of  greater  benefit  in the colder  areas  with Alaska
 being the case of point.

     Since EPA recognizes that the current FTP does not accurately
measure low temperature emissions it is  understood  that  the esti-
mated reductions  of CO  may not apply to Alaska or other low temper-
 ature areas.   With  the development  of  low temperature  test proce-
 dures the Agency is,  however, moving in a positive direction in its
 drive to reduce  low  temperature CO  emissions and will  continue to
 review  potential  alternative solutions  to  the  issue  presented.

     4.   Recommendations

     No changes  in  the regulations  are  recommended  in  response to
 these issues.

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